Half Moon Bay City Council
November 4, 2025

Medium Density Residential
This designation is primarily applied to neighborhood areas that are already substantially developed and have potential for infill development or redevelopment at densities comparable to those already existing. It is intended to be consistent with existing zoning for duplex and singlefamily development with a maximum density of 16 dwelling units per acre.

High Density Residential
This designation is intended to apply to areas suitable for, and already partially developed with, multi-family development or high-density single-family development, generally consistent with existing zoning for multi-family development with a maximum density up to 30 dwelling units per acre.

Mobile Home Park
This designation intends to protect and preserve existing mobile home parks, facilitate expansions of existing mobile home parks, and allow for possible designation of other appropriate sites for mobile home park development in the future. Mobile home park maximum density is 21 dwelling units per acre.

Workforce Housing Overlay
The Workforce Housing Overlay designation was established in the 2020 LCLUP update to facilitate affordable housing development on sites where residential development had previously been limited or prohibited. It is unmapped and applied through policy to specific parcels or portions of parcels suitable for medium- or high-density residential development with Horticultural Business, Rural Coastal, Regional Public Recreation, or Public Facilities and 272
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Institutions land use designations. Residential development allowed through this overlay must be affordable and maximum density is dependent on the underlying land use designation. For lands designated for agricultural uses, a Coastal Act priority use, the overlay is intended for farmworker housing. As applied to the Regional Public Recreation land use designation, the overlay would support housing for State Parks employees. For Public Facilities and Institutions, the overlay covers a broad range of public and quasi-public uses, including churches, schools, and some City-owned sites.

Planned Development
The Planned Development (PD) land use designation is given to generally large, undeveloped parcels and areas suitable for residential and/or mixed-use development, with possible inclusion of other uses including recreation, community services such as childcare, and other needed community uses such as assisted living facilities or healthcare uses. The purpose of the PD designation is to prevent piecemeal development and to re-plan old subdivisions by requiring that the entire area or parcel be planned as a unit. The use of flexible and innovative design concepts is encouraged. The LCLUP identifies specific guidelines for each PD area, including guidance for determining density and buildout.

The City has ten areas designated PD. Three are substantially developed and/or fully planned, primarily for residential development. Several of the remaining seven PD areas are characterized by habitat constraints and potential hazards. Thus, despite the amount of land potentially available for development in PDs, significant care is required through master planning to ensure compliance with the California Coastal Act and natural resource agency requirements while also protecting both the environment and any development from proximity hazardous conditions including coastal erosion and extreme fire severity zones. The Podesta Planned Development is centrally located near downtown and is less impacted by habitat and hazard constraints than other PD areas. It is included in the site inventory.

Commercial-General
This designation is intended to support a concentration of residential, services, and employment uses in central Half Moon Bay. Residential uses, with a maximum density equivalent to the Residential – High Density land use designation of 30 dwelling units per acre, are allowed throughout this designation. Development may be single-use residential, mixed-use residential with commercial uses, or single-use commercial. The allowed commercial uses include retail, service, and office uses, shopping centers, visitor-serving facilities, health care, and live-work spaces.

Commercial-Visitor Serving
This designation supports the City’s implementation of the California Coastal Act. It applies to areas suitable for commercial uses intended to serve the coastal recreational needs of visitors on sites near coastal recreational areas or along HWY 1. Uses may include visitor accommodations, restaurants, art galleries, equestrian supply, fishing and boating facilities, and other similar uses.

Small-scale neighborhood convenience businesses and service stations are also allowed. Single273 City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 7
and multifamily residential uses, with a maximum density equivalent to the Residential – Medium Density designation of 16 dwelling units per acre, are conditionally allowed in this designation provided that the primary use of the development is for visitor-serving uses.

Industrial
This designation allows for uses such as light industrial, distribution, repair, construction, and storage. Formerly, the Industrial land use designation did not provide for residential development; however, the 2020 LCLUP added allowances for mixed-use development consisting of light industrial uses with residential uses, such as in live-work configurations, at a density of up to 5 dwelling units per acre in addition to the underlying light industrial land use.

Policies of the Local Coastal Land Use Plan/General Plan Land Use Element In accordance with the Coastal Act, the City’s LCLUP sets forth policies related to development, public works, agriculture, coastal access and recreation, natural resource protection, community safety, cultural resource protection, and visual resource preservation. As presented in the Cycle 5 Housing Element, the 1996 LCLUP policies and Coastal Zone requirements posed significant constraints on residential development throughout the city. The 2020 LCLUP update sought to reduce those constraints utilizing new approaches to support development of housing broadly and affordable housing specifically. The approaches are backed up by policies crafted to harmonize restrictions imposed by the Coastal Act with state housing law and the local need for new homes. An overview of these new policies, as well as the primary areas of remaining policy constraints, is provided below. They are presented following the order of LCLUP chapters as noted for each section.

Framework and Development
LCLUP chapters 1 and 2, Framework and Development, lay the groundwork for the next two decades of development in Half Moon Bay. In addition to establishing land use designations, which were presented above, policies further reinforce the City’s intentions for the location, timing, and intensity of development of all types, including residential, throughout the city.

Social Equity and Environmental Justice
The California Coastal Act of 1976 supported lower-income coastal visitors and residents as follows:

Lower cost visitor and recreational facilities and housing opportunities for persons of low and moderate income shall be protected, encouraged, and, where feasible, provided. (Coastal Act Section 30213, as originally enacted.)
In 1981, SB 626 amended the Coastal Act, removing “and housing opportunities for persons of low and moderate income” from Coastal Act Section 30213. Section 30500.1 was also added, stating “No local coastal program shall be required to include housing policies and programs.” Due to these 1981 changes, many LCLUPs do not address affordable housing. This can lead to policy conflicts for many coastal cities, and for cities located entirely within the Coastal Zone, LCLUP and Housing Element policy can be difficult to harmonize. 274
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The ramifications of the 1981 amendments to the Coastal Act are evident throughout the Coastal Zone and have been studied in greater depth by the Coastal Commission over the past few years. A major milestone in reconsidering social equity and environmental justice occurred in 2019, when the Coastal Commission adopted a comprehensive environmental justice policy.1 Half Moon Bay’s LCLUP update includes Policy 1-5, Social Equity and Environmental Justice, which is consistent with the Coastal Commission’s policy:
1-5 Social Equity and Environmental Justice. Implementation of the LCP shall promote social equity and environmental justice, including the fair treatment and meaningful involvement of people of all races, cultures and incomes. a. When acting on a coastal development permit, amending the LCP, or otherwise implementing the LCP, the City shall consider environmental justice and, where applicable, the equitable distribution of environmental benefits throughout the state. The City shall encourage equitable civic engagement and social inclusion in public decision-making regarding coastal development, prioritizing efforts to reach low-income households and limited English-speaking households. b. No person shall be discriminated against by implementation of the LCP on the basis of race, national origin, ethnic group identification, religion, age, sex, sexual orientation, color, genetic information, or disability.

More recently, as of the drafting of the Cycle 6 Housing Element in June 2022, the Coastal Commission produced a comprehensive report, “Historical Roots of Housing Inequity and Impacts on Coastal Zone Demographic Patterns.” It is hoped that the Commission’s continued focus on equity and justice broadly, and on housing inequity in particular, will help Coastal Zone jurisdictions harmonize their Coastal Act obligations with state housing law and local housing needs. However, until this progress is reflected in legislation, the primacy of Coastal Act priority uses, which do not include affordable housing, will continue to be prioritized in the Coastal Zone and thereby impose a land use constraint for development of affordable housing.

Town Center
The 2020 LCLUP update established a defined Town Center where future development should be concentrated to support a vibrant and diverse mix of housing types (including affordable housing), businesses, shops, and public spaces. The area covers the central portion of the city, comprised of the city’s historic downtown, and the mixed-use and commercial areas to the north and south. More specifically, the Town Center includes all land designated Commercial – General, including the Main Street area and the land around the intersection of HWYs 1 and 92, as well as adjacent residential and mixed-use neighborhoods with other land use designations. The Town Center concept is foundational to the LCLUP’s land use policy strategy, prioritizing development within Town Center, the most resource-rich portion of the city. 1 California Coastal Commission Environmental Justice Policy, March 8, 2019, Environmental Justice Policy (ca.gov) 275
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Housing-Friendly Policies
The 2020 LCLUP introduced numerous housing-friendly policies intended to bolster housing production in a manner consistent with Coastal Zone requirements. The most relevant and impactful policies are presented in the following discussion with narrative indicating the significance of the policy with respect to the Housing Element and residential development, followed by the policy language in italics.

LCLUP Policy 2.3 Priority Land Uses defines affordable housing as a local priority land use. This determination establishes the importance of affordable housing over all other land uses except Coastal Act priority land uses. While this is a significant position in support of affordable housing development, the constraint remains in that Coastal Act priority uses will continue to be at the top tier. The policy language follows:
2-3. Priority Land Uses. Define priority land uses and support development of such land uses throughout the City by the following categories:
a. Coastal Act Priority Uses: Coastal-dependent uses, agricultural uses, visitor-serving commercial uses, and coastal access and recreational facilities. Coastal Act Priority Uses are considered top tier priority in this LCP; furthermore, as consistent with Coastal Act Section 30222, coastal-dependent industry and agriculture take precedence over all other uses including visitor-serving commercial recreation facilities.
b. Local Priority Uses: Affordable dwelling units for extremely low, very low, and lowincome households. Local Priority Uses are considered second tier priority behind Coastal Act Priority Uses in this LCP.

LCLUP Policy 2-5 Housing Element Conformance makes the provision of adequate sites for Half Moon Bay’s Housing Element a required consideration of the Coastal Commission in so far as the City’s LCLUP is the Coastal Commission’s standard of review for projects located within Half Moon Bay that come before it, such as those on appeal or associated with master planning and/or rezoning. The policy also focuses on housing sites in resource-rich areas and provides for housing types that are required to be affordable.
2-5. Housing Element Conformance. To ensure conformance with Coastal Act policies and priorities, focus the Housing Element’s inventory of adequate sites within Town Center and through the Workforce Housing Overlay land use designation.

LCLUP Policy 2-6 Housing Diversity and Affordability is a broad policy that inspired numerous other policies in the LCLUP to ensure that a wide range of housing types will be encouraged and compatible with various land use designations.
2-6. Housing Diversity and Affordability. Encourage a diversity of housing types, including housing at a range of affordability levels, densities, sizes, and ownership types with 276
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 10 equitable access to environmental benefits. Meet the needs of Half Moon Bay’s diverse population, including young families, multi-generational families, students, young professionals, and seniors.

LCLUP Policy 2-7 Housing Stock Preservation is another high-level policy that guides investing in housing rehabilitation programs, as well as for regulating short-term vacation rentals, which are a serious threat to housing stock inventory in the Coastal Zone. 2-7. Housing Stock Preservation. Safeguard existing housing stock so that it is preserved and used as full-time housing through the establishment of programs and ordinances.

LCLUP Policy 2-18 Minimum Residential Density Zoning Provisions will help ensure that Housing Element sites, as well as other properties, are not wasted on lower-density development proposals, such as single-family homes on lots suitable for triplex development. Minimum density provisions will also help the City make the most of its Below Market Rate Housing Ordinance (e.g., inclusionary zoning).
2-18. Minimum Residential Density Zoning Provisions. Establish minimum residential densities for areas with mixed-use zoning, specific plans, or precise plans within Town Center; and for all areas with R-3 zoning.

LCLUP Policy 2-19 Affordable Housing Density Bonus reinforces the City’s prior efforts to incorporate state density bonus law into the Zoning Ordinance. 2-19. Affordable Housing Density Bonus. Provide for density bonuses above the maximum densities cited for each residential land use designation, including mixed-use and PD designations, that provide for residential development consistent with California Government Code Section 65915, the Housing Element, and the Coastal Act, and when such increase in density does not adversely affect coastal resources.

LCLUP Policy 2-39 South Downtown Residential Priority supports single-use residential development in a substantial portion of the Town Center and provides policy support for increasing densities by redesignating numerous sites to the Residential – High Density land use designation which had been in the Residential – Medium Density land use designation. This will lead to up-zoning portions of the South Downtown area to the Multi-Family Residential (R-3) zoning district that are currently zoned Residential – Two-Family (R-2). 2-39. South Downtown Residential Priority. Maintain residential use as a primary use within South Downtown. Increase residential densities to encourage residential development of vacant sites along South Main Street and Poplar Street.

LCLUP Policy 2-70 Workforce Housing Overlay establishes this new land use designation in the 2020 LCLUP as an overlay to be combined through additional policies with several underlying 277
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 11 land use designations. Without the overlay, the underlying designations would not support significant amounts of housing, and in some cases, would have prohibited residential development. The policy further ensures that housing units enabled by the overlay are affordable and that the affordability and occupancy of the units by eligible households is enforceable such as through permit conditions or deed restrictions. 2-70. Workforce Housing Overlay. Occupancy of the residential development established through the Workforce Housing Overlay land use designation shall be limited to the workers specified in these policies and their households, subject to a use permit, deed restriction, or other mechanism designed to ensure the housing will be affordable to the specified workforce. This residential development shall further comply with the requirements established by policies for each qualifying underlying land use designation including Rural Coastal (Policy 2-92), Horticultural Business (Policy 2- 96), Public Facilities and Institutions (Policy 2-102), and Regional Public Recreation (Policy 2-105). Establish IP standards for implementing the Workforce Housing Overlay designation, including setbacks, height limits, and other requirements as consistent for compatibility with the underlying land use designation.

LCLUP Policy 2-73 Small Infill Lots continues the City’s efforts to facilitate development of infill parcels in established neighborhoods. Many of the remaining undeveloped parcels are substandard as to lot size or width. Program 2-4 in the Cycle 5 Housing Element encouraged development of two substandard lots per year for an overall goal of 16 sites. During that time 29 such sites moved ahead. Some substandard sites remain and LCLUP Policy 2-73 provides support zoning updates to further this effort.
2-73. Small Infill Lots. Update IP standards for substandard infill residential lots to encourage development of smaller homes that provide diverse and affordable housing options compatible with neighborhood character.

LCLUP Policy 2-74 Accessory Dwelling Unitsreinforces the City’s progress with accessory dwelling unit (ADU) production. During the Cycle 5 Housing Element, the City updated the ADU Ordinance twice. Policy 2-74 acknowledges the need to continue to keep the ordinance in conformance with State law over time and allows for an administrative review process for these units. The ADU Ordinance is presented in more detail below in the discussion of the City’s Zoning Ordinance. 2-74. Accessory Dwelling Units. Update IP standards as necessary to ensure that the Accessory Dwelling Unit ordinance complies with State law, provides for objective design standards, and allows an administrative review process provided there is no potential for impacts to coastal resources.

LCLUP Policy 2-75 Home Occupations supports employment opportunities for Half Moon Bay residents to conduct home-based businesses. This supports local cottage industries, reduces commute costs, and can help households with supplemental and/or primary income. 278
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 12 2-75. Home Occupations. Permit home occupations within residences for business types and activities that are compatible with the residential living environment and subservient to the primary residential use of each property. Establish performance standards in the IP for traffic, parking, noise, and other considerations with respect to home occupations.

LCLUP Policy 2-76 Short-Term Rentals establishes a framework for regulating short-term vacation rentals in Half Moon Bay. In the Coastal Zone, short-term rentals provide accommodations for coastal visitors and thereby support the Coastal Act’s mandate for maximizing public coastal access. The Coastal Commission has been supportive of short-term rentals in the Coastal Zone and treats them as a Coastal Act priority use. In Half Moon Bay, conversion of residences to fulltime short-term rental use has occurred, whereby homes are no longer used as dwellings.

Improperly managed short-term rental use sets up a conflict between coastal access and housing needs. LCLUP Policy 2-76 strives to resolve the conflict by supporting short-term rental use in a context where the use is subordinate to the primary residential use of the dwelling unit. As described in the later section addressing zoning considerations, the City vigorously and successfully sought Coastal Commission support for Short-Term Rental Ordinance regulations that comply with LCLUP Policy 2-76; however, the Commission has struck down similar shortterm vacation rental regulations in other Coastal Zone jurisdictions. Thus, the matter must be acknowledged as a potential ongoing constraint on the preservation of housing stock. 2-76. Short-Term Rentals. Allow short-term rental businesses within the established neighborhoods. Short-term rental uses should be subordinate to primary residential uses such that residential units continue to be used for long-term residential occupancy.

Establish land use regulations in the IP with performance standards necessary to protect coastal resources and the residential living environment of the neighborhoods, such as standards for property management, traffic, parking, noise, and trash. Short-term rental businesses shall pay transient occupancy tax to the City. Non-permanent housing such as for seasonal farmworker housing and short-term boarding for researchers and others employed or otherwise affiliated with agricultural uses are not short-term transient lodging facilities or uses and are not subject to transient occupancy tax.

Growth Management
Growth management requirements impose some of the greatest constraints on housing development in the city. Growth management is important in the Coastal Zone because the Coastal Act requires that infrastructure provisions, such as water supply, sewage treatment capacity, and roadway capacity, be reserved for Coastal Act priority land uses. Furthermore, infrastructure is not allowed to be expanded in such a way that it is growth inducing. Regulating the pace of growth is meant to ensure that infrastructure is adequate over time to accommodate new development while maintaining adequate capacity for future development of Coastal Act priority land uses. Growth management is addressed in policy in the updated LCLUP as presented 279
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 13 below. While inclusion of these policies in the LCLUP was necessary to ensure that the update is consistent with the Coastal Act, they impose significant constraints on housing development.

LCLUP Policy 2-16 Residential Growth Management presents the City’s residential growth control measure. In Half Moon Bay, residential growth is limited to, in any particular year, the number of dwelling units that would result in an increase of up to 1.5% of the city’s population as of January 1 of that year. This residential growth limitation was incorporated into the LCLUP by amendment after the passage of the voter initiative “Measure D” in 1999 and subsequent certification by the Coastal Commission in 2009, as well as recertification with the 2020 LCLUP update in 2021.

Because it is a ballot measure that was approved by the voters, Measure D can only be amended by a vote of the people (and subsequent certification by the Coastal Commission) or through State legislation. A more detailed discussion of Measure D can be found later in this chapter, in the section titled Residential Growth Limitations Ordinance. 2-16. Residential Growth Management. Provide for compatible and orderly residential growth at a managed pace and ensure that future development is consistent with the city’s growth management standards. Measure D (Residential Growth Limitation Ordinance) added the following provisions to the Land Use Plan and they may not be amended or repealed except by a majority vote of the people of Half Moon Bay as follows:
a. The number of dwelling units which the City may authorize each calendar year may not exceed the number of units which would result in a growth of 1 percent in the City’s population as of January 1 of that year. In determining the number of permissible units, the City shall use the most recent United States Census figures for Half Moon Bay to calculate the average number of persons per household. b. The number of dwelling units authorized each year under subsection a. may be increased by 50 percent for additional dwelling units in the Downtown Area. c. Applications for new units from areas of the City outside the Downtown Area have priority for one-half of the units authorized under subsection a. If fewer applications are received, the remainder of these units may be authorized in the Downtown Area. d. Subject to subsections b. and c., the city shall allocate permissible dwelling units among applications under the existing allocation system in the Municipal Code, to the extent feasible, and subsequent modifications by the City Council. e. The limitations in the Section shall not apply to replacement of existing dwelling units on a one-for-one basis, nor shall it apply to density bonuses for the provision of low and moderate income housing to the extent required by State law. f. The Downtown Area is the area designated as the Downtown Half Moon Bay Redevelopment Survey Area in City Resolution No. C-91-98, November 3, 1998.

LCLUP Policy 2-21 Lot Retirement was included in the 2020 LCLUP update to be consistent with the Coastal Commission’s past actions on applications for residential subdivisions in Half Moon Bay, and to allow the City to access over $2 million in lot retirement funds held by a condition of approval imposed by the Coastal Commission. Before the LCLUP update, the Commission considered several Half Moon Bay projects on appeal. In these cases, the Commission required 280
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 14 “retirement” of the same number of lots as were created through the subdivision to address the cumulative impacts of development on infrastructure. For example, a 10-lot subdivision of one lot would result in a net increase of nine lots. In such a case, the developer would be required to permanently “retire” nine potentially developable lots by conveying them to an open space land trust or through recordation of a conservation easement. When it established lot retirement requirements, the Coastal Commission was especially focused on mitigating the cumulative impacts of growth on the city’s limited circulation network because of impacts to public coastal access, which is a primary Coastal Act concern.

The City understood that the Coastal Commission would require a lot retirement policy in the 2020 LCLUP update. In an attempt to balance the interests of the Coastal Act with local housing needs, the City’s approach to lot retirement includes an exemption for affordable housing. The lot retirement policy is also not applicable to rental multi-family housing when subdivision is not involved. Despite these provisions, lot retirement increases the cost to develop market rate ownership housing; and such projects may be contributing affordable units through the City’s below-market rate inclusionary zoning provisions. Thus, the requirement for lot retirement must be acknowledged as a constraint.
2-21. Lot Retirements. Require mitigation for the individual and cumulative impacts of development when a new residential lot is created through retirement of development potential on an existing and separate lot, pursuant to the following criteria:
a. At least the same number of lots shall be retired as are created; b. The retired lot(s) shall be located within city limits and have potential for residential development, including lots with PD land use designations where residential development is a potentially permitted use;
c. Retirement of development potential may occur through recordation of a no-build restriction, an accepted offer to a land trust, or through an in-lieu fee to support such retirement; and
d. Deed restricted affordable housing shall be exempt from lot retirement requirements.

Planned Developments
The updated LCLUP strived to establish a process for master planning PD areas that would be both straightforward and comprehensive. As previously noted, these areas are generally large, lack infrastructure, and are impacted by hazards and/or environmental resources. While there are several LCLUP policies that address PDs, the following are most pertinent to the master planning process and address affordable housing as follows:

LCLUP Policy 2-46. Comprehensive Master Planning establishes the master planning requirements for Coastal Commission certification.
2-46. Comprehensive Master Planning. The entire PD area shall be comprehensively planned as a unit by the City or by an individual landowner(s) with a master plan as follows:
281
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 15 a. Master plans may be established as specific plans (Government Code Section 65450) or precise plans as guided by the Land Use Plan’s development vision for each individual PD. b. City-approved master plans shall be certified by the California Coastal Commission as an amendment to this Land Use Plan, with the policies of Chapter 3 of the Coastal Act as the legal standard of review.
c. In the case of any PD where portions are in separate ownership, approval may be given for development of a single parcel or group of parcels, provided that the City has approved and the Coastal Commission has certified a master plan for the entire PD area as required by the provisions of this section.

LCLUP Policy 2-47. Master Plan Site Assessment is meant to be a playbook for property owners and developers to follow to bring forward a well-planned, and approvable, PD area. 2-47. Master Plan Site Assessment. Require a comprehensive site assessment of the entire PD area as an initial or concurrent submittal for master plans. The assessment shall determine the net site area as the basis for determining residential and nonresidential buildout; consider the PD area in the context of the LUP’s development vision for each individual PD; present preliminary concepts for replatting if applicable; and identify methods for overall protection and enhancement of coastal resources. A preliminary assessment shall evaluate and identify (including as these topics are addressed in more detail in other LUP chapters):
a. Natural Resources. ESHA, required buffers, potential ESHA that may require future study, and identification of predevelopment that may have impacted or removed ESHA. If applicable, wetland delineation is a requirement for a complete application. In addition to required buffers, the assessment should consider what the ESHA needs to function properly (e.g. wildlife corridors, species diversity, habitat resiliency) as part of the plan for protection, as well the need to accommodate inland migration due to sea level rise or erosion.
b. Agriculture. Existing agricultural uses and approaches to retain such uses especially in cases of prime soils; locations for agricultural buffers from nonagricultural uses within the PD site plan design as applicable; and preliminary feasibility studies pursuant to Policy 4-9 with plans for mitigation in the case of proposed conversions of agricultural lands to new non-agricultural uses.
c. Environmental Hazards. Preliminary assessment and mapping of hazards, considering on- and off-site hazard risks and impacts, including but not limited to site contamination, flood, tsunami inundation, erosion (blufftop and banks of watercourses), sedimentation, fire, seismic and geotechnical conditions such as steep slopes and areas subject to landslide. In the case of bluff erosion, it must be established that development will not be subject to risk of loss from bluff erosion for its economic life. 282
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 16 d. Open Space. Locations for meeting the 20 percent open space requirement, and the City’s Parkland Standard in the case of residential development with at least half of the provision comprised of public open space.
e. Infrastructure. The provision of public services including water, sewer, and multi-modal circulation.
f. Access. Existing and proposed access points along Highways 1 and 92, primary interconnectivity routes within the PD and to other neighborhoods; and conceptual level plans for all primary modes of transportation including bicycle, pedestrian, and transit. g. Stormwater Management. Potential locations for and capacities of green infrastructure systems.
h. Visual Resources. Existing visual resource areas, including but not limited to scenic coastal access roads, the California Coastal Trail, broad ocean views, significant plant communities, and areas above the 160-foot contour line. i. Cultural Resources. Potential for archaeological and historic resources so that preservation can be addressed in the PD master plan.
j. Neighborhood Design. Potential land use conflicts such as noise and lighting; how new development can enhance, support, and/or connect to other neighborhoods; and ways to accommodate visitor access needs without impacting existing or new residential neighborhoods.

LCLUP Policy 2-57 Provisions for Housing Affordability is meant to ensure that residential development of these larger sites includes affordable housing units in alignment with the City’s ordinance requiring below market rate units (discussed later in Appendix B). 2-57. Provisions for Housing Affordability. New residential development in substantially undeveloped PDs shall be comprised of lower-cost development types with smaller units.

Lower-cost development types include medium-density small single-family homes, cottages, attached townhomes, live-work units, duplexes, triplexes, and garden apartments; and highdensity multi-family and mixed-use development. Generally, if single-family homes are proposed in a PD, they should be no more than 1,500 to 1,800 square feet. For PDs with 10 or more residential units, at least 20 percent of the residential units shall be deed restricted and made affordable to lower income households in perpetuity.

Public Works: Chapter 3, Public Works, of the LCLUP sets forth policies to address water supply, sewer capacity, and roadway systems. Water supply and sewage treatment capacity are reserved for Coastal Act priority uses first, and secondarily to the local priority use of affordable housing.

These uses are defined in the LCLUP as follows:
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 17 Priority Use, Coastal Act: Land uses that have priority over other uses for their location in the coastal zone, namely coastal-dependent uses, visitor-serving commercial uses, agricultural uses, and coastal access and recreation facilities.

Priority Use, Local: Uses that are considered second-tier priority behind Coastal Act Priority Uses in the Planning Area, namely affordable dwelling units for extremely low, very low, and low-income households.

The LCLUP includes growth projections to a 2040 planning horizon and a maximum theoretical buildout. Needed water supply, sewage treatment plant capacity, and circulation system impacts are studied for both growth scenarios. Water supply was found to be generally adequate, assuming implementation of strong conservation measures in the event of prolonged drought conditions, through the 2040 planning horizon, but not for maximum buildout. Sewage treatment capacity becomes impacted at the 2040 planning horizon. Transportation system capacity is impacted currently with AM and PM peak period weekday traffic volumes resulting in significant traffic congestion throughout town, especially along the HWY 1 corridor north of HWY 92 where level of service (LOS) is “F” and trips take three times longer than during “free flow” or off-peak periods. For the 2040 condition, delay increases to nearly a five-fold increase over the off-peak conditions. Thus, constraints on development are posed by all three systems and are discussed in more detail later in the constraints analysis.

To comply with the Coastal Act, the LCLUP’s public works policies limit infrastructure capacity including water supply, wastewater treatment capacity, and improvements to the roadway system to the levels necessary to serve development allowed under the LCLUP. Public works policies most impactful on housing development are presented below:

LCLUP Policy 3-1. Infrastructure Capacity establishes the City’s alignment with Coastal Act requirements to limit infrastructure to meet the needs of the maximum theoretical buildout of the LCLUP. This is not a significant constraint in that buildout of the housing sites inventory was accounted for in the LCLUP.
3-1. Infrastructure Capacity. New or expanded public infrastructure, including water, sewer, and transportation facilities, shall be designed and limited to accommodate needs generated by development or uses permitted consistent with this Land Use Plan and the Chapter 3 requirements of the Coastal Act.

LCLUP Policy 3-2. Monitor Growth and Infrastructure Capacity provides for annual checks on infrastructure provisions. It could lead to findings of inadequate capacity, such as on water supply during drought conditions.
3-2. Monitor Growth and Infrastructure Capacity. Monitor growth and infrastructure capacity annually for Coastal Act Priority Uses, Local Priority Uses, and Non-Priority Uses.

Publish reports summarizing changed conditions that may affect growth, infrastructure capacity, or the regulatory requirements associated with infrastructure and development. 284
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 18 LCLUP Policy 3-3. Coastal Act and Local Priority Uses aligns with LCLUP Policy 2-3 Priority Land Uses. Affordable housing, as a local priority use, takes precedence over many other uses for infrastructure capacity. Coastal Act priority uses are the top tier and thus are prioritized over most residential uses including affordable housing. Farmworker housing is an exception because it qualifies as a Coastal Act priority use. Policy 2-3 and 3-3 overcome significant constraints that held back affordable housing development during Cycle 5. 3-3. Coastal Act and Local Priority Uses. In the event that growth and capacity monitoring indicate that water supply and the associated classifications of water connections or sewer capacity will not be adequate to maintain public works capacity reservations for Coastal Act and Local Priority Uses or to support buildout of the Town Center, the City shall establish a public works capacity allocation process. In all cases, infrastructure reservations shall be prioritized according to the following tiering:

1. Coastal Act Priority Uses: Coastal-dependent, agriculture including farmworker housing, visitor-serving uses, recreation, habitat conservation/restoration, and essential services;

2. Local Priority Uses: Affordable housing;

3. Non-Priority Uses: Market-rate housing, general industrial, general commercial.

Allocations of infrastructure capacity for Non-Priority Uses will not be granted in the event that it would preclude development of Coastal Act Priority and Local Priority Uses.

LCLUP Policy 3-4. Town Center Infrastructure emphasizes the City’s strategy to concentrate development, including affordable housing, in the resource-rich center of town. This policy is meant to reduce constraints on development for the defined Town Center area, which was established based on the location of future and planned infrastructure and a wide range of public and commercial uses including schools, the library, grocery stores, healthcare, etc. 3-4. Town Center Infrastructure. The City shall plan for, fund through development impact fees and other sources, and implement infrastructure improvement projects or allocation systems, including for water, sewer, transportation, and stormwater, to support buildout of the Town Center.

LCLUP Policy 3-14. New Water Connections brought forth one of the most significant advances in support of affordable housing in the updated LCLUP. The local priority use designation made a finite number of lower-cost water connections available to affordable housing. These connections are held by the Coastside County Water District (CCWD) and cost about $17,000 each. Without this designation, water connections are available only via a secondary market of private property owners where the going rate at the time of the Housing Element update was estimated to be as much as $100,000 each. This makes for a significant reduction in the cost of infrastructure for affordable housing development. However, the constraint remains in that market rate residential development, which could support affordable units through the City’s below-market rate inclusionary requirements, must secure the higher cost water connections. 285
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 19 Thus, the limited number of available water connections and their cost are significant challenges to housing development.
3-14. New Water Connections. Support establishment of new water connections for the different use categories to serve sustainable development and LUP priorities for uses as specified:

1. Coastal Act Priority Uses: Coastal-dependent, agriculture including farmworker housing, and other Coastal Act Priority Uses with lower water demand;

2. Local Priority Uses: Affordable housing; and

3. Non-Priority Uses: Only after ensuring that efficiency measures for existing development meet or exceed conservation requirements or a reclaimed water supply is developed, and if development of such uses would not adversely impact other infrastructure systems, and if allocation of Non-Priority Use water connections would not preclude development of Coastal Act or Local Priority Uses.

If CCWD obtains a coastal development permit or permit amendment approving an increase in water supply or distribution capacity to provide additional service connections in excess of limitations imposed by conditions of approval for the Crystal Springs Phase 1 coastal development permit, the City shall encourage, or if the City issues the permit, shall require CCWD to not sell connections in advance of development proposals; and shall only approve such permit if robust assessment of the sewer, circulation, and stormwater management systems indicates that additional connections can be served by other infrastructure.

Agriculture: Agriculture is a Coastal Act priority land use. Maintaining lands with prime and subprime soils in active agriculture use is supported by the LCLUP. LCLUP Chapter 4, Agriculture, includes policies that discourage the conversion of agricultural lands and require mitigation for the loss of agricultural uses with prime and sub-prime soils to other uses. At the same time, the LCLUP also incentivizes continued agricultural uses by allowing for a wide range of supplemental uses. Farmworker housing is specifically recognized. The policies most applicable to the Housing Element and evaluation of constraints include the following:

LCLUP Policy 4-1 Agricultural Preservation sets the context for continued agricultural uses within the city limits. The policy stance is a constraint on housing development in that such lands might otherwise be seen as appropriate for conversion to residential development. However, the support for farmworker housing recognizes that ongoing viability of agricultural land use depends on the ability of farmworkers to live in Half Moon Bay and the San Mateo County Coastside. 4-1. Agricultural Preservation. Ensure the continued viability of agriculture within Half Moon Bay and the Planning Area. This shall include the following:
a. Protect existing agricultural operations and lands with prime and non-prime agricultural soils located outside of the Town Center, regardless of the underlying land use designation;
b. Accommodate the housing needs of farmworkers within the community; 286
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 20 c. Promote economic viability within Half Moon Bay by permitting agriculture compatible, supplemental, and ancillary uses that limit direct and cumulative impacts on the long-term productivity of agricultural soils (e.g. minimize soil disturbance and protect soil structure); and
d. Acknowledge potential land use compatibility challenges and allow flexibility for agricultural uses with regards to noise, dust, and other aspects of customary agriculture practices.

LCLUP Policy 4-4 Farmworker Housing establishes farmworker housing as both a Coastal Act and a local priority land use. As such, this housing type is a top priority for development in Half Moon Bay. The policy also allows for farmworker housing within the PD land use designation in advance of master planning of those areas. Overall, the restrictions associated with conversion of agricultural lands remain; however, the 2020 LCLUP update softens the constraint for farmworker housing.
4-4. Farmworker Housing. Farmworker housing is considered a Coastal Act Priority Use, as well as a Local Priority Use. Encourage a range of farmworker housing including nonpermanent housing for seasonal farmworkers and permanent housing through the Workforce Housing Overlay at appropriate affordability levels, densities, and locations on agricultural lands in Rural Coastal and Horticultural Business land use designations.

Encourage clustering of farmworker housing where feasible, especially to preserve prime agricultural soils such that it has the least impact on agricultural production. For agricultural and agricultural compatible uses in Planned Developments, allow for limited on-site affordable employee housing as provided for in the Planned Development designation in Chapter 2. Development.

LCLUP Policy 4-9 Conversion of Prime and Non-Prime Agricultural Land maintains the constraint associated with agricultural conversions and is consistent with the Coastal Act. 4-9. Conversion of Prime and Non-Prime Agricultural Land. Conversion of prime and nonprime agricultural land within the Town Center shall be permitted for anticipated urban development. Prohibit the conversion of prime and non-prime agricultural land outside the Town Center, including as shown on Figure 4-1, to a new non-agricultural use (excluding agricultural compatible and supplemental uses as defined in this chapter) unless all of the following can be demonstrated:
a. All agriculturally unsuitable lands on the parcel have been developed or determined to be undevelopable;
b. Continued or renewed agricultural use of the soils is not feasible as defined by Section 30108 of the Coastal Act;
c. Clearly defined buffer areas shall be provided on the site between the new nonagricultural use and adjacent agricultural uses to ensure the continued productivity of agricultural uses;
287
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 21 d. The productivity of any agricultural lands adjacent to the new non-agricultural use is not diminished; and
e. Public service and facility expansions associated with the new non-agricultural use will not impair agricultural viability, including by increased assessment costs or degraded air and water quality.

LCLUP Policy 4-10 Mitigation for Conversion of Agricultural Lands introduces the constraint of mitigation for conversions of agricultural lands to other uses; however, it also provides a means for mitigating conversions that will satisfy both the Coastal Act and CEQA requirements. 4-10. Mitigation for Conversion of Agricultural Lands. All conversions of prime and nonprime agricultural lands to a new non-agricultural use, excluding farmworker housing, agricultural compatible uses, and supplemental uses as defined in this chapter such as habitat restoration and recreation, shall be mitigated at a ratio to be established based on the quality of agricultural lands converted, their location, and other relevant factors as evaluated in a report prepared by a qualified professional for the City’s review and approval. Methods for mitigation may include but are not limited to establishing agricultural conservation easements, soil restoration, or in lieu fees in partnership with land trust and conservation agencies. Protection or restoration of agricultural lands within city limits is preferred; followed by lands within the coastal zone of unincorporated San Mateo County and finally by other coastal zone areas.

Coastal Access and Recreation: The California Coastal Act requires that public coastal access be maximized, and the California Constitution guarantees the public’s right of access to all beach areas below the mean high tide line. LCLUP Chapter 5, Coastal Access and Recreation, advances public coastal access throughout Half Moon Bay via coastal access routes and points; coastal access for all circulation modes including roadways and a network for multi-use trails; parking provisions for coastal visitors; and a wide range of coastal recreation uses. Many coastal access and recreation policies support residents in addition to visitors. For example, the trail network provides an important active transportation option for residents who commute and for running errands. Coastal access and recreation policies posing the most significant constraints on housing development include the following:

LCLUP Policy 5-46 On-Street Public Parking recognizes the City’s obligation to maintain public parking for coastal visitors. The City has less flexibility in reducing parking requirements for residential development than jurisdictions outside the Coastal Zone. Furthermore, transit provisions are limited and thus the entire Coastside tends to be auto-oriented for both visitors and residents. Parking requirements can be a constraint on housing development. 5-46. On-Street Public Parking. Protect and enhance the City’s on-street public parking supply, including by requiring new development to provide sufficient off-street parking and frontage improvements or payment of in-lieu fees to support such improvements. 288
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 22 LCLUP Policy 5-61 Parkland Standard presents the City’s Quimby Act parkland standard requirement of 5 acres per 1,000 residents. The standard applies to most residential subdivisions and is thus a constraint on some kinds of housing development. 5-61. Parkland Standard. Provide a minimum of 5 acres of City parkland including neighborhood and community park area for each 1,000 city residents, with additional parkland for specialized and low use park acreage. The parkland standard shall ensure that new development accommodates the recreational needs of future residents in pace with population increase.

LCLUP Policy 5-69 Development Priority for Visitor-Serving and Recreational Uses is consistent with LCLUP Policy 2-3 and 3-3 where Coastal Act priority uses are prioritized over other uses, including most types of housing.
5-69. Development Priority for Visitor-Serving and Recreational Uses. Prioritize visitororiented and recreational uses in all areas designated for Commercial Visitor-Serving on the Land Use Map. Encourage the addition of visitor-serving uses and overnight accommodations in these areas, particularly those that are lower-cost.

Natural Resources: The Coastal Act establishes policies for the protection of areas that are designated as environmentally sensitive habitat areas (ESHAs), including the marine environment and freshwater resources. LCLUP Chapter 6, Natural Resources, recognizes terrestrial ESHA (marine environment, sea cliffs, dunes, coastal terrace prairie, and non-aquatic habitat for special status and unique species); wetlands, and watercourses which may be riparian or non-riparian.

Numerous protected status species occur within these areas, including the San Francisco garter snake, California red-legged frog, western snowy plover, as well as the western monarch butterfly at several small overwintering sites. Rare native plants are also documented in Half Moon Bay’s ESHAs. The LCLUP includes a broad array of local policies consistent with the Coastal Act to protect ESHA and special status species. ESHAs limit development on numerous properties in the city due to buffers and other requirements. Moreover, natural resource protection requirements are significant constraints on all types of development in Half Moon Bay and throughout the Coastal Zone. Fortunately, the LCLUP’s strategy to concentrate new development within the Town Center provides several housing sites that are not significantly impacted by ESHA restrictions.

Hazards: There are policy provisions in the Coastal Act that minimize risks to life and property from various natural hazards. LCLUP Chapter 7, Environmental Hazards, includes policies per these provisions. Along the San Mateo County Coastside, hazard types are numerous, and all tend to be exacerbated by climate change. The LCLUP addresses shoreline hazards (coastal flooding, shoreline erosion, tsunami events, and seawater intrusion); geologic and seismic hazards (erosions and sedimentation, landslides, subsidence, liquefaction); fluvial flood hazards (localized flooding and inundation caused by dam or impoundment failure); and fire hazards. Of note, the Cycle 5 Housing Element included a housing site in a very high fire severity zone. The 289
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 23 LCLUP update improved hazard mapping which informed the site inventory for the Cycle 6 Housing Element. Hazards are a significant constraint on development; however, once again, when concentrating new development within the Town Center, hazards are either avoided or can be mitigated.

Cultural Resources: Archeological sensitivity areas are mapped in the LCLUP Chapter 8, Cultural Resources. Areas most sensitive are along watercourses. Most sites within the Town Center are not mapped for resource sensitivity, and this constraint is limited to only a few properties within the key vacant and non-vacant sites inventory.

Visual Resources: Coastal scenic and visual resources are protected by the Coastal Act. LCLUP Chapter 9, Scenic and Visual Resources includes policies for protecting designated scenic and visual resource areas including scenic corridors (Town Boulevard Corridor, scenic coastal access routes, broad ocean views, and the California Coastal Trail); natural resources (beaches and shoreline, significant plant communities, open space conservation areas, and upland slopes); and the built environment (Heritage Downtown, substantially underdeveloped PDs, and parks).

Broadly, visual resource protection policies can be addressed for pipeline projects and key vacant and non-vacant sites through thoughtful site planning. Specific examples of the most relevant policies are presented below.

LCLUP Policy 9-12 Town Boulevard Scenic Corridor requires that viewsheds from HWYs 1 and 92 to protect scenic and visual resources including the ocean and upland hillsides be maintained.

This policy will require visual analysis for some Housing Element sites that are located near these corridors. However, building heights and setbacks needed to retain views will not impact buildout to the realistic yields evaluated for the site inventory. The constraint is therefore associated with the development review process, but not with the ultimate development of housing sites. 9-12. Town Boulevard Scenic Corridor. Require that new development in close proximity to or easily visible from the Town Boulevard scenic corridor, including Highways 1 and 92:
a. Protects views of visual resource areas as seen from the Town Boulevard, including views to the ocean, upland slopes (i.e. minimizes intrusions into the ridgeline), and the historic Johnston House;
b. Incorporates design standards such as screening of commercial parking areas and landscaping provisions; and
c. Is visually compatible with the surrounding land and development.

Update the IP with additional standards for new development along the Town Boulevard based on additional study of the scenic corridor. Assessment should, at a minimum, consider views of visual resource areas from the perspective of existing and potential development along the Town Boulevard and identify scenic segments along Highway 1 and 92, including views of the ridgelines and other visual resource areas. Development standards should address, at a minimum, appropriate building heights and setbacks, longest wall lines, minimum space between buildings, and streetscape design. 290
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 24 LCLUP Policy 9-13 Highway 1 and 92 Frontages will also apply to the development review process but should not result in a reduction in unit yield for any inventory sites. For example, the Hilltop Mobile Home Park expansion on the north side of HWY 92 will require sound protection from the highway. A sound barrier can be incorporated into a frontage landscape treatment and would result in complying with both Policy 9-3 and with noise standards. 9-13. Highway 1 and 92 Frontages. Improve the appearance of the Highway 1 and 92 frontages as properties redevelop through the following means:
a. Establish build-to lines to frame and define the transportation corridors. b. Reduce visual clutter by consolidating utilities, phasing out monument signs, and requiring permanent maintenance of frontage landscaping.

LCLUP Policy 9-15 Scenic Coastal Access Routes addresses sites on specified streets that connect HWY 1 to public beaches. The Hatch Elementary School site, located on the southwest corner of HWY 1 and Kelly Avenue will need to adhere to policy 9-15. Modest setbacks are anticipated to be more than adequate to accomplish this, and the site analysis shows that this will not affect realistic yield. This policy will impose limited constraints on residential development for this site and other potential development locations. 9-15. Scenic Coastal Access Routes. Require that new development on designated scenic coastal access routes from Highway 1 to the beach, including roadway improvements and development proposed in close proximity to the road, protects the scenic quality of the corridor and avoids obstruction or significant degradation of public ocean views such as through provision of sufficient setbacks from the public right-of-way, low building heights, and landscaping that establishes and/or maintains a scenic gateway.

LCLUP Policy 9-23 Upland Slopes and Ridgelines primarily affects parcels front HWYs 1 and 92 and is addressed through site planning as described for Policies 9-12 and 9-13. 9-23. Upland Slopes and Ridgelines. Protect broad views of upland slopes, prominent ridgelines and other intervening ridgelines as viewed from scenic corridors and the beach and shoreline through the following means:
a. Prohibiting new development above the 160-foot contour line and on slopes greater than 30 percent, including grading and subdivisions but excluding public trails and critical facilities or public infrastructure that cannot be located elsewhere;
b. Ensuring new development below the 160-foot contour line is sited and designed to minimize intrusions into the ridgeline through the application of appropriate height and setback restrictions; and
c. Establishing standards for the Town Boulevard, other streetscapes, and large-scale landscaping projects to highlight and frame, but not block, views of visual resource areas.
291
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 25 LCLUP 9-25 Heritage Downtown applies to a portion of the Town Center characterized by a high concentration of historic buildings. Some pipeline projects are in this area, but none of the key vacant and non-vacant sites are in Heritage Downtown. The significance of Heritage Downtown and its associated historic resources may constrain redevelopment in this area due to the intent to preserve historic resources. However, Heritage Downtown is a small portion of Town Center, and the few vacant lots that remain are being developed with mixed-use residential and commercial buildings. Three pipeline projects represent this trend. 9-25. Heritage Downtown. Preserve and enhance the architecture, landscape, scale and ambiance of the Heritage Downtown visual resource area through design review of new development, redevelopment, and streetscape improvements. Design review shall consider:
a. Compatibility with scale and style of predominant older structures; b. Continuity in building lines maintained along Main Street; c. Maintaining key architectural features in proposed alterations to existing older buildings; and
d. Avoiding demolition of existing older buildings that contribute significantly to the character of the area.

LCLUP Policy 9-28 Substantially Undeveloped Planned Developments applies to the largest key vacant and non-vacant site, the Podesta Planned Development. Preliminary plans for this site indicate that development will not block views to upland slopes or the ocean. The site is also not affected by significant plant communities or a scenic coastal access route. Thus, for the sake of this important Housing Element site, this policy will not be a constraint. The policy will serve as a constraint within some of the other PD areas, especially those on the west side of HWY 1 because they are located on scenic coastal access routes and/or could interfere with protected public views of the ocean. In those cases, adequate setbacks, clustering development, and care with building heights will be required. None of those other PDs are included in the Housing Element site inventory.
9-28. Substantially Undeveloped Planned Developments. Require projects proposed in substantially undeveloped Planned Developments (PDs) to assess visual resources and provide a visual impact evaluation as part of the master planning process for developing the PD in accordance with Chapter 2. Development. PDs shall be planned to protect public views of visual resource areas (e.g. broad ocean views, scenic coastal access routes, upland slopes, significant plant communities) and minimize adverse visual impacts as consistent with all applicable policies of this chapter. Following master planning and substantial development, the PD as a whole is no longer considered a visual resource area.

The approved master plan shall continue to designate and protect other visual resource areas in Figure 9-1 (e.g. broad ocean views) through siting and design of new development and redevelopment projects.
292
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 26 Zoning and Subdivision Ordinances
The City’s Zoning Code and Subdivision Ordinances comprise the Implementation Plan (IP) of the LCP to implement the LCLUP in a manner consistent with the California Coastal Act. This analysis presents the zoning and subdivision provisions as currently stand in the IP. When applicable, the discussion acknowledges how intended amendments to the IP will affect constraints. Appendix A of the LCLUP includes a detailed summary of the required implementation measures that will update the Zoning and Subdivision Ordinances. It is also notable that the LCLUP policy supports its own implementation:
1-2. Coastal Resource Protection Priorities. Protection of ESHA, public access and other coastal resources are a high priority for the City. To the extent that any policies in this Land Use Plan (which serves as the City’s General Plan Land Use Element) and other elements of the City's General Plan are ambiguous, the City shall interpret them in the way that best protects ESHA and other coastal resources and maximizes public access. In advance of updating the Implementation Plan for Half Moon Bay - Local Coastal Land Use Plan Chapter 1: Introduction and Framework 1-44 conformance with the policies of the 2020 Land Use Plan, the policies of the Land Use Plan shall provide the standard of review for any proposed new development, including where these policies are more protective of ESHA and other coastal resources and maximize public access as consistent with the Coastal Act.

Amendments to the Zoning Code and Subdivision Ordinance require Coastal Commission certification following City adoption. The process for doing so is well-supported by the LCLUP which was recently certified in whole and unanimously by the Coastal Commission as explained in the previous section.

Zoning Districts
Residential development is allowed in most of the City’s zoning districts. Four residential districts and four mixed-use districts hold most of the city’s housing stock. Three additional zones allow for some residential development, either on a limited basis or through a master planning process.

Table B-1 presents the relationship of land use designations, described above, to zoning districts, described in this section.

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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 27 Table B-1: LCLUP/General Plan Designations and Zoning Districts that Allow Residential Use LCLUP/General Plan Land Use Designation Zoning Districts Residential Designations and Districts
Low-Density Residential Pending*
Medium-Density Residential R-1, R-1-B-1, R-1-B-2, R-1-B-3, R-2 High-Density Residential R-3
Mobile Home Park Mobile Home Park (MHP)
Mixed-Use Designations and Districts
Commercial-General C-G, C-D, C-R
Commercial-Visitor Serving C-VS
Industrial Industrial Land Use; Pending*
Other Designations and Districts
Rural Coastal Urban Reserve (U-R); Pending*
Horticultural Business A-1
Planned Development Planned Unit Development
Workforce Housing Overlay Pending*
Source: City of Half Moon Bay LCLUP and Zoning Ordinance. *Notes: Pending zoning amendments to implement the LCLUP will affect and/or replace several of the City’s zoning districts:
 Low Density Residential: This will be a new zoning district for lands in extreme fire hazard areas and/or rezone PUD areas to standard zoning with the same density.
 Industrial Land Use: Allowances for mixed-use with residential development will be added.  Rural Coastal: Most sites in the Urban Reserve (U-R) zone and Open Space Reserve (OS-R) zone (which currently does not allow residential development) will be rezoned to a new district consistent with the new Rural Coastal land use designation.
 Workforce Housing Overlay: This will be a new overlay/combining zoning district implementing the new Workforce Housing Overlay land use designation.

Residential Zoning Districts: The residential zoning districts provide appropriately located areas for residential development that are consistent with the LCLUP/General Plan Land Use Element.

The residential districts include:

Single-Family (R-1, R-1-B1, R-1-B-2, and R-1-B-3): These are the City’s single-family zoning districts with minimum lot sizes ranging from 5,000 square feet to 10,000 square feet.

Two-Family (R-2): This district allows duplexes and single-family development with a 5,000 square foot minimum lot size. The minimum density is 10 dwelling units per acre, and maximum density is 16 dwelling units per acre.

Multi-Family (R-3): This is the City’s multi-family residential zoning district. It allows multifamily rental and ownership housing as well as duplexes and single-family homes. The minimum lot size is 5,000 square feet. The minimum density is 15 dwelling units per acre and the maximum density is 29 dwelling units per acre.
294
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 28 Mobile Home Park (MHP): This district establishes standards for development and expansion of the city’s mobile home parks. Mobile homes make up almost 10% of the city’s housing stock and the maximum density is 22 dwelling units per acre.

Mixed-Use Zoning Districts: All of the City’s commercial districts allow single-use residential and mixed-use development. These include:

Commercial Downtown (C-D): This district establishes a range of uses and development standards that maintain and are consistent with the historic patterns and pedestrian scale of development within the historic downtown. In 2020, the City updated the C-D provisions to eliminate the requirement for a use permit for single-family, multi-family, and mixed-use residential development in this zone. The maximum density is 29 dwelling units per acre.

Commercial Residential (C-R): This district provides a transition zone between the active commercial district and single-family residential areas. Development is limited to residential, low-intensity professional offices, and semi-public uses. The 2020 zoning update also eliminated the use permit requirements for single-family, multi-family, and mixed-use development in this zone. Maximum density is 29 dwelling units per acre.

Commercial General (C-G): This district guides the orderly development of commercial areas designated for a full range of retail, service, and commercial and professional office businesses serving both residents and visitors. Again, the 2020 zoning update eliminated the use permit requirements for single-family, multi-family, and mixed-use development in this zone. The minimum density is 15 dwelling units per acre and the maximum density is 29 dwelling units per acre.

Commercial Visitor Serving (C-VS): This district designates recreational commercial areas that serve the needs of coastal visitors, and emphasizes coastal access, recreation, overnight accommodations, retail, and restaurants. Single-family dwellings and mixed-use development with residential units on upper floors are allowed with the issuance of a use permit provided that the units are ancillary to a primary permitted commercial use oriented to coastal visitors; multi-family dwellings are not allowed. The maximum density is 16 dwelling units per acre.

Additional Zoning Districts: Residential development is also allowed in the following zones as described here:

Urban Reserve (U-R): This district is applied to most of the city’s lands in field crop agriculture use. It allows for one dwelling unit for the owner, manager, or operator of the operation (e.g., the “farmhouse”) subject to a use permit with a minimum site area of 15 acres per unit. In addition to a farmhouse, employee housing is also allowed. Lands in the U-R zoning district will be rezoned to the forthcoming Rural Coastal district which will enable the LCLUP. The Rural Coastal district will include the Workforce Housing Overlay for most sites. 295
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 29 Agricultural Land Use (A1): The city’s greenhouse horticulture operations are in the A1 zone.

As an accessory use to permitted horticulture uses, single-family residential development is permitted, including homes for help employed on the premises. For the first unit, the building site must be at least one-half acre; two dwellings are allowed on parcels over five acres; and an additional unit is allowed for each additional three acres, with a limit of four units.

Planned Unit Development (PUD and PUDX): The PUD zoning district provides for a variety of land uses, including residential development. Master plans, such as specific or precise plans that plan the area as a whole, are required prior to development. Master plans establish land use, density, and infrastructure provisions to guide development in these areas. The Half Moon Bay City Council has approved various projects in the PUD areas. However, the amount of development approved by the City Council has been reduced by the Coastal Commission as part of its consideration of appeals of coastal development permits or through settlement agreements. The PUD areas have been mastering planned and substantially developed with residential uses include the following:

Table B-2: Buildout of Planned Unit Developments that have been Master Planned Master Planned
Planned Unit Developments
Developed
(Units)
Potential for Additional
Housing (Units)
Ocean Colony 568 single-family
68 multi-family
8 single-family
Approx. 40 multi-family
Andreotti 129 multi-family Built out
Amesport Landing 90 multi-family Built out
Main Street Park 64 multi-family (all affordable) Built out Pacific Ridge (Dykstra Ranch) 19 single-family 44 single-family Miramar Beach (Casa Mira) 14 multi-family Built out
Matteucci 11 single-family
3 ADUs
2 single-family
Several more ADUs
Stoloski-Gonzalez 1 single-family 3 single-family
Several ADUs
Source: City of Half Moon Bay LCLUP, GIS, and permit files.

Seven substantially undeveloped PUD areas remain that have not been master planned. The PUD master planning process is described later in the Permit Processing Procedures, Timelines, and Fees section of this discussion.

Rezoning: Implementation zoning needed for both the Housing Element and LCLUP will add mixed-use standards for the industrial zoning district, the new Rural Coastal zoning district, new provisions to implement the Workforce Housing Overlay land use designation, and a new low-density residential zoning district applicable to two specific areas impacted by hazards and/or environmental constraints. Table B-3 summarizes the residential development standards for all the zoning districts allowing residential uses presented above.

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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 30 Table B-3: Development Standards by Zoning District
Zoning
Distric
t
Min. Site Area
(Lot/Unit)
(SF or AC)
Min. Avg.

Site
Width
(Lot/Unit
) (Ft)
Fron
t
Yard
Setback
(Ft)
Side
Yard
Setback
(Ft)
Rear
Yard
Setback
(Ft)
Max.

Height
(Single/
Multistory)
(Ft.)
Lot
Coverage
(Single/
Multistory) (%) FAR
Residential Zoning Districts
R-1 5,000 SF 50 20 5 20 20/28 50%/35% 0.5:1
R-1-B1 6,000 SF 60 25 5 20 20/28 50%/35% 0.5:1
R-1-B2 7,500 SF 75 25 6 20 20/28 50%/35% 0.5:1
R-1-B3 10,000 SF 90 25 20%
lot
width
20 20/28 50%/35% 0.5:1
R-2 5,000 SF/2,500
SF
50/25 20 5 20 20/28 50%/35% 0.5:1
R-3 5,000 SF/1,500
SF
75 20 5 20 20/40 50%/45% N/A
MHP 5 AC/2,000 SF N/A 20 10-20 20 N/A N/A N/A
Mixed-Use Zoning Districts
C-R 5,000 SF 50 20 5 20 28 50%/35% 0.5:1
C-D 5,000 SF 50 0-5 0-5 0-5 36 N/A N/A
C-G 10,000 SF 100 Single-family refers to R-1; two-family refers to R-2; multi-family refers to R-3, mixed-use per Planning
Commission.

C-VS 10,000 SF 100 Single-family refers to R-1; mixed-use per Planning Commission; multi-family not allowed.

Additional Zoning Districts Allowing Residential Uses
U-R 50 AC/15 AC N/A Dependent on the location of agriculture operations or structures.

A-1 15 AC/0.5 AC 100 Dependent on the location of agriculture operations or structures.

PUD/
PUDX
Per master plan.

Source: City of Half Moon Bay Zoning Ordinance
*Note: Height limits and lot coverages for one-story structures in the R-1, R-2, and R-3 zoning districts are 20 feet and 50%, respectively. For multi-story structures, maximum height is increased, and maximum lot coverage is decreased; e.g., for the R-1 and R-2 zoning districts, the two-story height limit is 28 feet and lot coverage limit is 35%; and for the R-3 zoning district, the multi-story height limit is 40 feet, and the lot coverage limit is 45%. 297
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 31 Zoning for a Variety of Housing Types
Housing Types Defined in the Zoning Code: The Zoning Code provides for a variety of residential housing types listed below.

Single-Family Dwelling: Buildings containing one dwelling unit located on a single lot. This classification includes manufactured homes and lots containing a primary dwelling unit, an ADU, and/or a junior ADU.

Accessory Dwelling Unit (ADU): An attached or detached residential dwelling unit.

Two-Family Dwelling/Duplex: A building containing two dwelling units. This classification includes manufactured homes.

Multi-Family Dwelling: A building containing three or more dwelling units. This classification includes manufactured homes.

Mixed-Use: Combination of nonresidential and residential uses located on the same property as part of a unified development.

Manufactured Home: A modular housing unit on a permanent foundation that conforms to the Manufactured Housing Construction and Standards. A mobile home is considered a manufactured home.

Group Residential: Shared living quarters without separate kitchen or bathroom facilities for each room or unit. This classification includes boarding houses and private residential clubs, but excludes residential hotels or motels.

Residential Care, Limited: Twenty-four-hour non-medical care for six or fewer persons in need of personal services, supervision, protection, or assistance essential for sustaining the activities of daily living. This classification includes only those services and facilities licensed by the State of California. Note: This type of facility is commonly termed a small group home.

Transitional Housing: Buildings configured as rental housing developments, but operated under program requirements that require the termination of assistance and recirculating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no less than six months from the beginning of the assistance.

Supportive Housing: Housing with no limit on length of stay, that is occupied by the target population, and that is linked to an on-site or off-site service that assists the supportive housing 298
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 32 resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community.2 Residential Care, General: Twenty-four-hour non-medical care for seven or more persons, including wards of the juvenile court, in need of personal services, supervision, protection or assistance essential for sustaining the activities of daily living. This classification includes only those services and facilities licensed by the State of California. This type of facility is commonly termed a large group home.

Emergency Shelter: Means housing with minimal supportive services for homeless persons that is limited to occupancy of six months or less by a homeless person. No individual or household may be denied emergency shelter because of an inability to pay.

Convalescent Facilities: Establishments providing twenty-four-hour care for persons requiring regular medical attention, excluding facilities providing surgical or emergency medical services.

The development potential by zoning district for each of the previously listed housing types is presented in the following table.

2 Target Population. Means adults with low income having one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health conditions, or individuals eligible for services provided under the Lanterman Developmental Disabilities Services Act (Division 4.5 commencing with Section 4500) of the Welfare and Institutions Code) and may, among other populations, include families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, or homeless people.
299
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 33 Table B-4: Housing Types Allowed by Zoning District
Housing Type by
Zoning District R-1-X R-2 R-3 MHP C-D C-R C-G C-VS A-1 U-R PUD/
PUDX
*
P-S
Single-family YES YES NO YES YES YES UP YES UP * RZ
ADU YES YES NO YES YES YES YES RZ RZ * RZ
Duplex NO YES NO YES YES YES NO RZ RZ * RZ
Triplex,
Fourplex NO YES (R-3) NO YES YES YES NO RZ RZ * RZ
Five plus Units NO YES NO YES YES YES NO RZ RZ * RZ
Mixed-Use NO NO NO YES YES YES UP YES YES * RZ
Manufactured
Home YES YES YES YES YES YES YES YES YES * RZ
Small Group
Home YES YES NO UP UP YES NO NO NO * RZ
Large Group
Home NO UP NO UP UP UP NO NO NO * RZ
Group
Residential NO UP NO UP UP YES NO NO NO * RZ
Transitional
Housing YES YES NO NO NO NO NO NO NO * RZ
Supportive
Housing YES YES NO RZ RZ RZ NO RZ RZ * RZ
Emergency
Shelter NO NO NO NO** NO NO NO NO NO * YES
Convalescent
Facilities NO UP NO UP UP YES NO NO NO * NO
Employee
Housing*** RZ RZ NO RZ RZ RZ RZ (UP) RZ UP * RZ
Source: City of Half Moon Bay LCLUP and Zoning Ordinance  Key: NO = not allowed; YES = allowed; UP = allowed subject to a Use Permit; RZ = Pending Rezoning will allow; RZ(UP)= Pending Rezoning will allow with Use Permit
 *PUD/PUDX districts: Residential use types per master plan.  **The Coast House shelter was established in the C-D zoning district via Project Home Key land use allowances, where shelters are otherwise not permitted uses.
 ***Employee Housing with six or fewer employees, as defined by the Employee Housing Act.

Additional Zoning Considerations for Needed Housing Types: Additional considerations for the above housing types and household needs are further described below. These housing types and populations are important considerations for the Cycle 6 Housing Element and are identified in the following discussion in relationship to the site inventory. 300
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 34 Accessory Dwelling Units (ADUs): ADUs are regulated by Zoning Ordinance Section 18.33.030, Accessory Dwelling Units. The City updated the Accessory Dwelling Units Ordinance twice during the Cycle 5 Housing Element period. The 2018 and 2022 updates brought the ordinance up to State housing law as it was frequently amended in recent years. Each update was certified by the California Coastal Commission and submitted to HCD for consistency review. For ADUs comprised of new “development” as defined by the California Coastal Act, the ordinance provides for streamlined administrative coastal development permits.3 ADUs established within the habitable floor area of existing development are exempt from a coastal development permit. ADU production has increased steadily following the 2018 ordinance update. Before the update, there had been only three units per year; production quickly increased to ten units per year followed by over twenty, with sustained property owner interest expected to maintain these levels of development.

Manufactured Homes: Manufactured homes are permitted in any residential district subject to the same development standards for setbacks, lot coverage, height limits, etc. In the residential zones, Zoning Ordinance section 18.06.060, Manufactured homes, includes basic objective design standards and quality requirements related to recent manufacture. Development potential is high, and the City has approved all applications received during the Cycle 5 Housing Element period for manufactured homes, which have consisted of single-family residences on infill lots. Manufactured homes must be placed on a permanent foundation.

Multi-family Housing: Multi-family housing is a permitted use in the R-3 zone. It is also a permitted use in the C-R, C-D, and C-G zones in single-use (residential only) or mixed-use (residential typically with commercial uses) development formats. Basic development standards for R-3, C-R, C-D, and C-G zones are presented in Table B-3, above. All these zoning districts have a minimum density of 15 units per acre and a maximum density of 29 units per acre.

The City’s development standards allow multi-family housing to be constructed at the maximum allowed densities. The minimum lot size, height allowance, and setbacks allow projects to maximize development and achieve allowable densities. The City also allows development standards to be waived or relaxed for affordable projects. Parking requirements are discussed separately below. The City’s standards for multi-family housing do not present a constraint to the development of apartments, townhouses, condominiums, or other multi-family uses and do not 3 California Coastal Act section 30106: “Development” means, on land, in or under water, the placement or erection of any solid material or structure; discharge or disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste; grading, removing, dredging, mining, or extraction of any materials; change in the density or intensity of use of land, including, but not limited to, subdivision pursuant to the Subdivision Map Act (commencing with Section 66410 of the Government Code), and any other division of land, including lot splits, except where the land division is brought about in connection with the purchase of such land by a public agency for public recreational use; change in the intensity of use of water, or of access thereto; construction, reconstruction, demolition, or alteration of the size of any structure, including any facility of any private, public, or municipal utility; and the removal or harvesting of major vegetation other than for agricultural purposes, kelp harvesting, and timber operations which are in accordance with a timber harvesting plan submitted pursuant to the provisions of the Z'berg-Nejedly Forest Practice Act of 1973 (commencing with Section 4511). 301
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 35 have a negative impact on housing supply.

Facilities for Disabled Households: For the Cycle 5 Housing Element, to ensure compliance with SB 520, the City's zoning laws, practices, and policies were thoroughly evaluated as a part of the update process. At that time, the requirement for an accessory dwelling to obtain a use permit was the only constraint identified. The Accessory Dwelling Unit Ordinance update in 2018 removed the use permit requirement. Program 1-2 is informed by input from local service providers to better address these needs, including reasonable accommodations. This is especially important in that 10% of the city’s population have a disability, which is significant and somewhat higher than the countywide average of 8%.

The City’s Zoning Ordinance allows small group homes (limited to 6 or fewer persons) for day care or residential care in all residentially zoned districts without a use permit. Residential care and daycare facilities for 7 or more persons are allowed in the R-3, C-G, C-D, and C-R zones with a use permit. Group residential facilities, which provide for shared kitchen and plumbing facilities, but individual living space for persons or households, are permitted by right in the C-G district and with a use permit in the C-D and C-R districts. The only condition for a use permit for these various types of facilities, if applicable, is that the use be limited to non-medical care. Program 3- 9 requires zoning updates to ensure that group homes, be they small (for 6 or fewer residents) or large (for more than 7 residents), and similar facilities are defined and provided for in the residential and mixed-use zoning districts.

There are no specific constraints or additional requirements imposed for developments that assist disabled households. For example, there is no minimum distance requirement between residential care facilities, and there are no occupancy standards that apply specifically to unrelated adults. “Family” is defined as two or more persons living together as a single housekeeping unit in a dwelling unit, provided that this shall not exclude the renting of rooms in a dwelling unit as permitted by district regulations. The rental clause is directed at the requirement that mobile home units within mobile parks be limited to use as permanent residences and may not be rented for less than 30 days. Parking standards for housing for disabled persons are the same as all residential development and do not pose a constraint on development of housing for disabled persons. However, the Zoning Code allows for the removal or reduction of development standards for affordable housing, including affordable housing for disabled households.

Half Moon Bay follows the requirements of the Americans with Disabilities Act (ADA) regarding the development of accessible housing. Housing rehabilitation assistance and accessibility improvements are provided through the County’s housing rehabilitation program and the Center for the Independence of the Disabled for qualified residents. The Zoning Code includes provides for exceptions for minor improvements for disabled access (Zoning Ordinance 18.06.050.I). The procedure requires the submittal of an application, plans that depict the accommodation, citations of the codes that need to be waived, limitations on the scope of the adjustments, and 302
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 36 findings. These requests are processed by staff and are not subject to a public hearing. Program 1-2 requires evaluation and update of these allowances to ensure they are adequate.

Facilities for Homeless and Households at Risk of Homelessness: Facilities and housing for homeless persons and those at risk of homelessness fall into three categories: Emergency shelters, Transitional housing, and supportive housing.

Emergency Shelter (per Health and Safety Code 50801): Zoning for emergency shelters was added to the Zoning Ordinance in 2015. Emergency shelters are a permitted use in the P-S zoning district. In addition to the P-S zoning provisions, San Mateo County, with the City’s support, purchased the Coastside Inn, a hotel located in the C-G zoning district, with CARES Act funds. The 52-room hotel was converted into the Coast House shelter. The shelter is operated by Life Moves and is the first shelter on the San Mateo County Midcoast. Per Program 3-7, emergency shelters will also be a permitted use in the Industrial zoning district.

Zoning - Development and Operational Standards
There are no unique development or operational standards in the zoning code describing emergency shelters. They are subject to the same development and operational standards as other uses in the P-S and Industrial zoning districts, as per state law.

Zoning – Siting and Proximity to Transportation and Services Upon completion of LCLUP implementation, the P-S zoning district will be comprised of approximately 120 acres on about 20 parcels. Most of those sites are now substantially developed, targeted for future development, or encumbered via significant environmental factors. Notably, affordable housing is proposed on three of these sites (See Appendix C- Housing Resources, Sites AJ, 1, and 2), and therefore the zone has limited capacity for an emergency shelter. Program 3-7 specifies adding emergency shelters as a permitted use to the Industrial zoning district. With the LCLUP update, this zone is now mixed use and will comprise approximately 30 acres on about 16 parcels, most of which are located in the City’s Town Center, close to services and other amenities. Three parcels in this zone, totaling about 3.5 acres, are currently vacant and located within the City’s Town Center. Others are only partially developed. Allowing emergency shelter use in the Industrial zoning district will provide adequate capacity for the City’s future need of this use, which is anticipated to be an additional shelter beyond the provisions provided at the Coast House.

Zoning - Hazardous Conditions
There are no identified hazardous conditions on any of the parcels in the commercial zone that would interfere with an emergency shelter or shelters suitable to support the number of unsheltered homeless persons in Half Moon Bay (68 individuals).

303
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 37 Zoning - Human Habitability
There are already several residential developments in the P-S zoning district and mixed use developments in the Industrial zoning district, as well as active commercial businesses.

Zoning – Feasibility
The three vacant parcels in the Industrial zone contain 3.5 acres. This does not include underutilized buildings or parking lots. This is more than enough underutilized space to meet Half Moon Bays needs, in addition to the City’s role in supporting the Life Moves shelter already located in the city. Transitional Housing (per Health and Safety Code 50675.2(h)):

Zoning for supportive housing was added to the Zoning Ordinance in 2015. Transitional housing is a permitted use in the residential zoning districts including all the R-1 zones, as well as the R-2 and R-3 districts. The residential zoning districts comprise over 650 acres and there are numerous developed and undeveloped lots to accommodate this use.

Supportive Housing (per Health and Safety Code 50675.14(b)): Zoning for supportive housing was added to the Zoning Ordinance in 2015. Supportive housing is a permitted use in the residential zoning districts including all the R-1 zones, as well as the R-2 and R-3 districts. The residential zoning districts comprise over 650 acres where there are numerous developed and undeveloped lots to accommodate this use. Program 3-7 will modify Sections 18.07,

18.08, 18.11, and 18.13 to allow permanent supportive housing as a use by-right (nondiscretionary) in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651.

Low Barrier Navigation Center: Low barrier navigation centers are temporary shelters with low barriers to entry as defined by California Government Code 65660. Recent State Law (AB 101) AB 101 requires that low-barrier navigation centers be allowed as a permitted use in areas zoned for mixed-use and nonresidential zones permitting multi-family uses. The City has not yet zoned for low barrier navigation centers. Program 3-7 identifies that the City will need to establish a definition for low barrier navigation centers and add them as a permitted use to the Industrial district once it is updated to allow multi-family residential uses in mixeduse formats.

Extremely Low-Income: Extremely low-income households can be housed in affordable housing developments with deep subsidies, such as Section 8 or Section 232. These types of units are most likely to be constructed in the R-3 zone, on publicly owned housing sites, and/or on sites designated with the new Workforce Housing Overlay land use designation. Other housing opportunities for extremely low-income households include housing with shared facilities, such as living or dining areas, with private sleeping areas, and are often referred to as single room occupancies (SROs). This type of development allows rents to be much lower than those associated with typical apartment complexes. The Group Residential use allows for facilities such as SROs and is permitted in the C-G zone by right and in the C-D and C-R zones with a use permit.

There are vacant sites currently zoned R-3, or planned for rezoning to R-3, that can accommodate 304
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 38 multi-family apartments and group residential uses. Sites in the C-G, C-D, and C-R zones also allow multi-family development and group residential uses. The implementation of the LCLUP, specifically with the application of the Workforce Housing Overlay, will result in numerous additional sites that will be suitable for affordable housing development including units for extremely low-income households. Several of those sites are in public ownership, including the City-owned 555 Kelly Avenue and 880 Stone Pine Road sites, and the Hatch Elementary School site.

Housing for Agricultural Employees (permanent and seasonal): The A-1 district permits singlefamily dwellings that are accessory to the primary permitted uses that include nurseries, greenhouses, and field flowers. This housing can include buildings for help employed on the premises. The U-R district allows for employee housing with a use permit. The Open Space Reserve (OS-R) district also allows agricultural uses; however, it does not allow farmworker housing.

The LCLUP established the new Rural Coastal land use designation. To implement the LCLUP, a new Rural Coastal zoning district will be established. Both the U-R and OS-R zones will be retired and most of the lands in these areas will be put into the new Rural Coastal zone when it is established. The Rural Coastal zone, as well as the A-1 zone and portions of the P-S zone, will be updated with zoning to establish the new Workforce Housing Overlay land use designation. This will provide for both permanent and seasonal housing on multiple properties in development formats and densities that will also preserve prime and subprime agricultural soils as required by the Coastal Act.

Female Headed Households: The primary need for female-headed households is affordable housing with supportive services, including childcare. In pre-development discussions with affordable housing developers, City staff identify sites where childcare would be most appropriate and encourage the developers to include childcare in their programming. Many local affordable housing developers have experience with such provisions. Several of the site inventory properties have the potential to include supportive services and childcare. The Podesta Planned Development site is identified in the LCLUP as having high potential for housing development with community uses, including childcare.

Employee Housing: Currently, employee housing is only allowed in the UR district, “as housing for those persons employed on the premises” subject to a use permit per Section 18.11 of the zoning code. Program 3-4 will modify Sections 18.06, 18.07, 18.08, 18.09, and 18.13 for employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone, consistent with the Employee Housing Act.

Program 3-4 will also modify Sections 18.13 and 18.14 of the Zoning Code to allow employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zones (A-1 and A-2 zones, respectively). 305
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 39 The Employee Housing Act (HSC Sec. 17021.8) requires cities to provide a streamlined, ministerial approval process for certain agricultural housing developments in land designated as agricultural.

Currently, HSC Sec. 17021.8(a)(2)(A) exempts streamlined agricultural employee housing in the Coastal Zone (which encompasses Half Moon Bay). If this exemption is rescinded by State law, the City will develop a process compliant with SB 3035 (2024) to ministerially process certain types of agricultural housing.

Affordable Housing Zoning Provisions
The Zoning Ordinance supports housing and affordable housing development through provisions presented below:

Development Standards: Section 18.06.050(H) of the Zoning Code states that development standards for residential uses may be waived or relaxed for an affordable housing project. This provision allows developers much flexibility in designing affordable housing projects. Minimum lot sizes, widths, setbacks, parking, and other requirements can be reduced or waived, as long as the resulting development conforms to the certified LCP and other applicable provisions of the Zoning Code outside of Chapter 18.06. Using this provision, the City reduced parking requirement standards for the Lesley Gardens development, which includes units specifically designed for disabled and senior households. The Government Code includes Sections 65590 to 65590.1 that specifically pertain to housing in the Coastal Zone. Section 65590(d) requires local governments to offer density bonuses or other incentives, including, but not limited to, modification of zoning and subdivision requirements, accelerated processing of required applications, and the waiver of appropriate fees for low- and moderate-income housing in the Coastal Zone. Program 1-4 states that the City will continue to provide incentives for affordable housing. A number of the programs contain provisions directly supporting affordable housing development, including Program 1-3 which provides for the Below Market Rate Housing Ordinance requirements and the affordable housing fund Program 1-4 which calls for updating the Residential Density Bonus Ordinance; and Program 4-6, which covers additional affordable housing resources.

Below Market Rate Housing Ordinance (Inclusionary Zoning): Half Moon Bay’s Below Market Rate Housing Ordinance comprises Chapter 18.35 of the Half Moon Bay Zoning Code. The ordinance requires either the construction of dwellings that very low-, low-, and moderateincome households can afford to rent or buy, or the contribution of an in-lieu fee to the City’s affordable housing fund in an amount sufficient to provide affordable housing opportunities for these income groups. The below market rate (BMR) provisions are consistent with Government Code Section 65590(d) which requires new developments in the Coastal Zone to provide housing for persons and families of low- and moderate-income, where feasible, and if it is not feasible, to provide the units elsewhere in the jurisdiction within three miles of the Coastal Zone.

Under the ordinance, ownership residential development projects of ten or more lots or dwelling units, or the conversion of ten or more rental units to condominiums, are required to provide 20% of the units as affordable units in the following ratios to the extent practical and feasible:
306
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 40  6% affordable to very low-income households
 7% affordable to low-income households
 7% affordable to moderate-income households
The planning commission and city council may modify these targets based upon the specifics of each new residential subdivision of ten or more lots or dwelling units or condominium conversion projects of ten or more units. In those cases where strict adherence to the formula provided herein results in a fraction between one one-hundredth and forty-nine one-hundredths of a below market rate dwelling unit, the city council may approve a pro rata contribution to the affordable housing fund an amount equal to twenty percent of the building permit valuation for the market rate units to be built. Where the fraction of a below market rate housing unit was between five-tenths and ninety-nine one-hundredths, an additional housing unit shall be required (18.35.020 D through F).

Incentives for providing below market rate housing are described in Zoning Code section

13.85.050. These include reduction or waivers of development standards, priority use of water and sewer, and incentives for units with three bedrooms or more. Additional incentives will be considered as part of Program 1-3.

The Below Market Rate Housing Ordinance does not describe its relationship with State Density Bonus Law. Program 1-3 directs the modification of the ordinance to clarify that State Density Bonus Law allows for bonuses in addition to, not in competition with, the City’s Below Market Rate Housing Ordinance.

The Below Market Rate Ordinance only applies to ownership housing projects of 10 or more units, which is a very small fraction of developments in Half Moon Bay. The City is interested in expanding the program’s applicability to rental housing developments and in lowering the threshold for when BMR units are required from ten units to a lower level, such as five units. For smaller market rate developments, the City would further consider establishing an affordable housing impact fee. These considerations are captured in Program 1-3.

There are two recent applicable developments, both of which are subdivisions. In Carnoustie, a multi-phase project, the developer paid an in-lieu fee for six affordable units. This established the City’s affordable housing fund. In the Creekside subdivision, the developer is going ahead with four affordable units to meet the inclusionary requirements.

BMR requirements could potentially be considered a constraint to developing housing because developers might choose to develop elsewhere rather than have the responsibility of providing affordable units. It is also possible that, due to the relatively small sites in Half Moon Bay with buildout potential near the program threshold of ten units, a developer may lower a project’s unit count to avoid the BMR requirements. To counter this potential, minimum residential densities are already included in the City’s multi-family and mixed-use zoning districts, but they 307
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 41 are not required for lower density subdivisions. In Half Moon Bay, the market is so desirable that the Below Market Rate Housing Ordinance has not constrained development; however, the City’s intent to deepen the requirements needs to be carefully studied to ensure that this remains the case.

The City is considering working with 21 Elements on both commercial and residential countywide nexus studies. These studies will likely be completed by the end of 2026. This is also described in Program 1-3.

Housing Element programs outline the following actions and improvements to the BMR requirements to ensure economic viability and improve BMR yield.  Program 1-3 provides for an economic analysis of Below Market Rate Housing Ordinance updates including making the requirements applicable to rental housing, lowering the threshold for ordinance applicability, establishing an affordable housing impact fee for smaller projects, and assessing the effectiveness of the City’s minimum density requirements. This program also encourages development of BMR units on-site to the extent feasible.
 Program 1-4 addresses incentives and options for development of BMR units to offset hardships or burdens that may be imposed by the requirement, including those concessions available through the Residential Density Bonus Ordinance.  Program 6-2 addresses oversight and preservation of BMR units, such as by:
 Monitoring the units annually.
 Ensuring that rents, sales prices, and income limits are maintained.  Guiding the marketing of units and selection of occupants.

Residential Density Bonus Ordinance: The City’s Residential Density Bonus Ordinance comprises Chapter 18.42 of the Zoning Code. The ordinance complies with Government Code Sections 65915 through 65917 by reference, as it exists as of 2022 or may hereafter be amended. The ordinance provides density bonuses and incentives, including updated parking standards based on unit size, affordability, and proximity to transit for qualifying developments. The density bonus provisions are supported by policy in the recent LCLUP update. Density bonuses were also accounted for in the LCLUP update buildout assessments. Density bonus units that may come forward through Housing Element implementation are therefore foreseen and found to be consistent with the Half Moon Bay LCP provided that such developments including density bonus units are also in compliance with coastal resource protection policies.

Additional Zoning and Subdivision Considerations
Residential Growth Limitations Ordinance (Measure D)
In 1991, the voters of Half Moon Bay passed a residential growth limitation initiative titled Measure A. This initiative limited new residential units to 3% of the population growth rate annually. In 1999, the city’s voters passed Measure D which amended the residential growth cap 308
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 42 to a 1% population increase annually, which can be increased by an additional 0.5% for units in a designated Downtown Area. Reasons cited for reducing the population growth rate included concerns that residential taxes would not cover the cost of basic services, traffic impacts on HWYs 1 and 92, and other critical infrastructure limitations including water supply and sewer capacity.

In 2001 and 2002, the City Council approved amendments to the LCLUP, the Subdivision Ordinance (Chapter 17.06 Residential Dwelling Unit Allocation System), and the Zoning Ordinance (Chapter 18.04 Residential Growth Limitations) which reduced the number of annual allocations that could be issued consistent with Measure D. The measure went into effect in 2009 after an extensive review by the California Coastal Commission to certify it as an amendment to the LCP. Thus, although Measure D was passed in 1999, it was not effective until 2009.

Residential growth is limited to, in any particular year, the number of dwelling units that would result in an increase of 1% of the city’s population as of January 1 of that year. US Census data is used to calculate the average number of persons per household (PPH) to convert the allowed population growth to a specific number of units. The number of dwelling units may be increased by another 0.5% in the Downtown Area at the discretion of the City Council. Council has approved this increase since 2009; and thus, in practice, Measure D accommodates 1.5% annual population growth. The following are exempt from the Residential Growth Limitations Ordinance:
 Replacement of existing dwelling units on a one-for-one basis  Density bonus units associated with the provision of low- and moderate-income housing as required by State law
It is important to note that ADUs have not been exempted from the regulations. Section 65852.2(a)(2) of the Government Code requires that a second unit ordinance not be considered in the application of any ordinance, policy, or program to limit residential growth. The City sought to address this in the Cycle 5 Housing Element through Program 2-3 which intended to revise the Zoning Code to clarify that ADUs are not subject to the Residential Growth Limitations Ordinance, consistent with the requirements of Government Code Section 65852.2(a)(2). However, in putting forth that code amendment for California Coastal Commission certification, for the proposed modification, the Coastal Commission report identified that while 65852.2 applies to local ordinances, LCPs are not “solely a matter of local law, but embody state policy.”4 Thus, because the City’s growth control measures were incorporated into its LCP to protect coastal resources, maintain coastal access, and preserve infrastructure capacity consistent with the obligations of the California Coastal Act, Coastal Commission staff determined that population growth associated with the development of ADUs must continue to be regulated within the construct of Measure D.

Pertinent to the Cycle 6 Housing Element, approximately 582 allocations can be issued from January 2023 through December 2030. Based on the formula established by Measures D and set forth in the Subdivision and Zoning Ordinances, the “end of year projected population” in Table 4 California Coastal Commission, July 2014, item F7a, HMB-1-11, pages 25 – 27. 309
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 43 B-5 is used to determine the allowed population growth for the next year of up to 1.5%, which assumes 1% citywide and an extra 0.5% for the Downtown Area. The number of allocations available for the next year is then calculated by dividing the increase in population by the city’s average PPH from the U.S. Census.

Table B-6: Projected Cycle 6 Residential Unit Allocations as of 2023 Year
Start of Year
Estimated
Population a
New
Unitsb
Additiona
l Personsc
End of Year
Projected
Population

1.5%
Populatio
n
Growthd
Following
Year
Allocationc
2023 11,946 50 129 12,075 181 70
2024 12,075 50 129 12,204 183 71
2025 12,204 50 129 12,333 185 72
2026 12,333 50 129 12,462 187 72
2027 12,462 50 129 12,591 189 73
2028 12,591 50 129 12,720 191 74
2029 12,720 50 129 12,849 193 75
2030 12,849 50 129 12,978 195 75
Total 582
a. 2023 “Start of Year Estimated Population” derived from City of Half Moon Bay City Council Staff Report “2023 Residential Dwelling Unit Allocation,” December 6, 2022; where 2023 start of year population is projected to be 11,946. For this analysis, 2023 population growth is assumed to be 129 persons based on 50 residential building permits. b. Estimated number of building permits issued each year. If building permit issuance is substantially lower (i.e., 25/year), Cycle 6 allocations would be 565; if building permit issuance is substantially higher (i.e. 70/year or approximately equivalent to the annual number of available Measure D allocations), Cycle 6 allocations would be 604. c. Assumes persons per household (PPH) of 2.58, based on 2020 U.S. Census. d. Assumes 1% maximum allocation citywide and an additional 0.5% in the Downtown Area.

In addition to the 582 allocations available to be issued during Cycle 6, additional allocations had already been issued prior to the start of the cycle, for which development permits had not yet been issued. As of January 1, 2023, this included 32 allocations for the Hilltop Mobile Home Park, almost half the allocations needed for the City’s 555 Kelly Avenue affordable housing site, almost 20 allocations for several downtown infill mixed-use and multi-family projects, and many more allocations for single-family homes and ADUs throughout the city. Because the time clock for allocations stops during the entitlement and approval process and resumes when entitlements have been issued, it is anticipated that these allocations will carry over into the Cycle 6 RHNA period before the permits for the projects are fully approved and/or the projects are developed.5 This process is described further in the Use of Allocations section below. As shown, the City’s available and previously issued allocations should be adequate to accommodate the City’s 480- unit RHNA with respect to capacity.
5 These projects are included in Technical Report Appendix C – Housing Resources as Pipeline Projects. 310
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 44 Allocation Process: Each December, the City establishes the number of allocations that can be granted the following year. In years when there are fewer applications than allocations, allocations can be granted throughout the year on an over-the-counter basis. This was the case for most of Cycle 5. However, in association with significant updates to the Accessory Dwelling Unit Ordinance, initially in 2018 and again in 2022, the number of Measure D applications has steadily increased due to a strong uptick in ADU development. During such periods of elevated development activity, applicants seeking allocations are encouraged to apply in January, allowing the City to determine if there will be enough allocations for the residential projects most likely to proceed during that calendar year. If there are not enough allocations, as occurred in 2021, 2022, and 2023, a scoring and ranking procedure is triggered.

If on January 31, there are more applications than allocations, applications are scored using a point system. Each project is scored based on project location, which is either within the Downtown Area or outside of the Downtown Area; and project type, which is either residential development (ADUs, single-family residential, duplex, or multi-family per section 17.06.100) or subdivision (land divisions that include residential development per section 17.06.200).

The scoring system prioritizes projects that include affordable units, are located on infill sites, are higher density, and/or incorporate sustainability measures. Projects located outside of the Downtown Area compete with other projects outside of the Downtown Area for a number of allocations that would support up to 1% of the city’s allowed annual growth. This includes onehalf of the allocations associated with the 1% growth limit, with the addition of a 0.5% bonus as provided for by the ordinance for the Downtown Area. The result is that twice as many allocations are available for projects located in the designated Downtown Area. The Community Development Director reviews and scores applications by April 1. The scores and rankings are subsequently presented to the Planning Commission at its first meeting in April. The Planning Commission’s role is to ratify or modify the Director’s recommendations.

The application scoring standards for residential development and subdivision projects are summarized as follows:

Residential Development (maximum 246 points available per section 17.06.120)

1. Infill Sites (maximum 70 points, includes 35 points for inclusion of BMR unit(s))

2. Home Size, Scale, and Clustering (maximum 30 points)

3. Design for Walking and Bicycling (maximum 37 points)

4. Design for Safety & Social Gathering (maximum 15 points)

5. Design for Diverse Households (maximum 20 points)

6. Resource-Efficient Landscaping (maximum 74 points)

7. Subdivisions (maximum 463 points available per section 17.06.200)

1. Water (maximum 20 points)

2. Sewer (maximum 20 points)
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 45

3. Drainage (maximum 15 points)

4. Schools (maximum 78 points)

5. Fire Protection (maximum 35 points)

6. Police Department Services (maximum 55 points)

7. Streets, state highways, and pedestrian improvements and amenities (maximum 45 points)

8. Open Space (maximum 35 points)

9. Park and Recreation Facilities (maximum 40 points)

10. Affordable Housing (maximum 100 points)

11. Architectural Design and Landscaping (maximum 20 points) Residential projects involve infill development on existing subdivided lots within the urbanized area of the city that are served by existing infrastructure. Subdivision projects involve new development that may require the extension of infrastructure and may extend development beyond the urbanized area of the city in some cases. For these reasons, subdivision projects have more demanding standards. The standards provided are intended to ensure that development projects have adequate infrastructure, provide for their fair share of municipal services, and that development projects are designed to encourage safety of residents. As discussed, the standards prioritize affordable projects by providing a relatively high number of points for projects that include affordable units. Because projects receive points commensurate with each development’s percentage of affordable units, fully affordable projects will be the most competitive in the process. The scoring criteria also favor projects with reduced energy demand and greenhouse gas emissions, primarily by prioritizing in-fill development, especially development in the Downtown Area.

Use of Allocations: Measure D allocations are valid for one year from the date of issuance.

Expiration is governed by Section 17.06.050 of the Half Moon Bay Subdivision Ordinance. While the City does not allow “rollovers” of unused allocations, an allocation can be extended beyond one year to accommodate permitting timelines, including regulatory delays such as those associated with review by resource agencies. The clock stops while projects are in review with active applications for planning or building permits. Developers may apply for allocations prior to applying for entitlements or during the entitlement process. This flexibility helps developers plan entitlement and construction timelines and reduce the risk of allocations going unused. As discussed below, developers can also enter into a phasing agreement with the City to extend allocations over a period of time. The City Council may also grant a one-year extension.6 The
system ensures that allocations continue to be valid over the course of project review. 6 There is no fee to request an extension, and the extension request does not require any findings from the City Council. Because the City stops the clock during any processing of entitlements (which includes City entitlements such as a Coastal Development Permit, subdivision map, lot split, use permit, design review, and other agency approvals, such as water connections), an extension would only be requested when a developer either wants additional time to request entitlements or if a developer has received entitlements but wants to wait to construct the units. This does not add cost to the development process, nor does it delay a development project. The City Council has not rejected any requests to extend the time period for a growth allocation. 312
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 46 Development Phasing Agreement: Developers may enter into a phasing agreement with the City at any time during a year. A phasing agreement guarantees the developer a specific number of allocations for a project and removes the need for the developer to apply for allocations on an annual basis. Developers of larger projects do not need to apply for growth allocations and time extensions as discussed above, if instead, they enter into a development phasing agreement with the City. This process guarantees the number of allocations a development project will receive over a specified time span, thereby reducing the risk and uncertainty for a developer.

Development phasing agreements must be approved by City Council at a noticed public hearing.

Other developers and projects are noticed of the request for the phasing agreement so they can comment on whether it would adversely affect their projects.

The development phasing agreement provides for a project to receive a greater number of annual allocations in any category by deducting those allocations from future years. Alternatively, a development phasing agreement may provide for a project to receive a specific number of allocations each year for a set number of years. Applicants with development phasing agreements do not need to compete for points to receive annual allocations for multiple years, and are guaranteed a specific number of allocations through the agreement, providing certainty, and reducing the overall risk associated with the entitlement process. While this process may reduce a constraint for the project benefiting from the phasing agreement, it will reduce the number of allocations available in future years, which could constrain other development proposals.

Measure D Outcomes: The Residential Dwelling Unit Building Permit Allocation System (Chapter

17.06 of the Subdivision Ordinance) would be considered a constraint on housing if it impedes the development of units needed to meet the city’s housing needs. The City has considered this potential constraint from the perspective of capacity and implementation.

Capacity: The city’s housing needs, based on the 2023-2031 Regional Housing Needs Allocation (RHNA), total 480 units. With the 20% buffer required by HCD, the total is 576 units. The estimated 586 allocations that may be available during the 2023 through 2031 timeframe are sufficient to accommodate the RHNA and the buffer. Further, density bonus units are exempt from the allocation that will allow the very low-, low-, and moderate-income units to be developed without an allocation, should the developer request a density bonus. Therefore, from the perspective of overall capacity, Measure D should not be a constraint to the provision of sufficient housing units to meet the city’s housing needs.

Implementation: While the 582 allocations that will be available during this RHNA cycle should be more than adequate to accommodate the 480 units of the City’s fair share of regional housing needs, program implementation imposes significant constraints, especially for larger projects.

However, from year to year, the City cannot predict the full demand for allocations from private development, which makes it difficult to make thoughtful decisions about phasing agreements.

Managing the supply of allocations within the strict construct of the Measure D regulations has 313
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 47 only become more challenging as interest in ADUs has shot up. This is coupled with certification of the comprehensive update to the LCLUP which enabled numerous new sites for housing development, including publicly owned sites most suited for affordable housing. Developers contemplating larger projects have expressed concern about the availability of allocations and are unsure of how to phase buildout for these cases. For the last two years of Cycle 5, ADUs consumed over half the allocations and there were not enough allocations for all the units proposed. In particular, several single-family projects have been required to wait and reapply in future years. This type of delay results in pent-up demand with projects reapplying for allocations are competing with new projects.

Measure D and its implementation regulations present an obstacle to the development of housing necessary to accommodate the City’s fair share of regional housing needs. In Cycle 5, the Housing Element included a program (Program 2-9) that required an annual evaluation of the Residential Dwelling Unit Allocation System. With the increase in ADU development and opportunities for larger projects, including affordable housing projects, in compliance with Cycle 5’s Program 2-9, City staff informed City Council that Measure D was modestly restricting housing development in the near-term, and that more significant impacts on larger projects may be looming. In 2024, staff presented potential ways to update the Measure D regulations to modestly ease these constraints and more fully prioritize affordable units over all others; however, as a ballot initiative incorporated into the City’s certified LCP, much of Measure D cannot be amended without a vote of the people and subsequent LCP amendment. Programs 6- 4 and 6-8 in the Cycle 6 Housing Element would address Measure D were it to constrain RHNA production. These programs commit the City to evaluate potential amendments to Measure D with the City’s intent to embark on revisions to allocation requirements for ADUs and JADUs.

Substandard Lots
There are a significant number of residential lots in the city that do not conform to the minimum lot size and lot width requirements necessary for development. These lots are considered substandard or severely substandard, depending on the degree to which a lot does not conform to the size and width requirements of the Zoning Code. Severely substandard lots are defined as any lot that provides 55% or less of the required lot width or lot area.

The Cycle 5 Housing Element estimated that there were approximately 200 substandard and severely substandard lots in the City’s R-1 and R-2 residential zoning districts. In years past, development of these lots had been difficult due to relatively restrictive zoning requirements and they were thus less favored because of the remaining availability of standard sized lots. However, the vast majority of standard sized residential zoned lots are now developed. The City prioritizes infill development, and with many of the remaining undeveloped lots tending to be small or otherwise constrained, the City sought to ease zoning requirements to facilitate housing development. To that end, the Zoning Ordinance was first updated in 2011, with subsequent clarifying updates. Parking standards for both substandard and severely substandard lots were adjusted to allow one garage space, where two are otherwise required. The second space for 314
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 48 these lots can be accommodated without a garage. Setbacks for severely substandard lots were also reduced, allowing for much more usable floorplans on these especially narrow lots.

Table B-7: Single-Family Residential Zoning Regulations for Standard and Substandard Lots Zoning
District
Min Standard Lot
Size/Width (SF/FT)
Substandard Lot
Size/Width (SF/FT)
Max Severely Substandard
Lot Size/Width (SF/FT)
R-1 5,000 / 50
Between standard and
severely substandard
2,750 / 27.5
R-1-B-1 6,000 / 60 3,300 / 33.3
R-1 B-2 7,500 / 75 4,125 / 41.25
R-1 B-3 10,000 / 90 5,500 / 49.5
R-2* 5,000 / 50 2,750 / 27.5
Source: City of Half Moon Bay Zoning Ordinance
*R-2 lot sizes in the above table are for single-family development in the R-2 Duplex zoning district. Duplex development requires 2,500 square feet of site area and 28.5 feet of lot width per unit.

During the Cycle 5 Housing Element, about 30 substandard lots in the residential zoning districts were developed. Thus, for Cycle 6, the City estimates that approximately 170 substandard and severely substandard undeveloped lots in R-1 zoning districts remain that could accommodate a single-family home, and possibly also an ADU or junior ADU.

The R-3 and mixed-use districts also include substandard lots that can benefit from the relaxed regulations for substandard and severely substandard lots. They are treated similarly to those presented above for the R-1 and R-2 zoning districts where the minimum lot size is 5,000 square feet. However, that applies only to single-family development. The City seeks multifamily and/or mixed-use development in these districts to maximize buildout, and parking provisions tend to be a more significant constraint, as described below, for these zones and “missing middle” (e.g. duplexes, triplexes, garden apartments) housing development.

Parking Requirements
Chapter 18.36 of the Zoning Code establishes parking standards. Zoning provisions for parking include:
 Affordable Housing: Exceptions to the parking standards for affordable housing projects are allowed.
 Hardships: Exceptions to the parking standards in cases of practical difficulties and unusual hardships are allowed.
 Joint Use Parking Facilities: Joint use of parking facilities is allowed, provided that the total number of parking spaces supplied collectively is not less than the sum of the requirements for the various uses computed separately.
 Off-site Parking: Off-site parking provisions are allowed provided subject to findings about location and ownership/agreements.
 Low Parking Demand Developments: For projects that demonstrate lower than typical parking demand, such as senior and disabled parking, the City will reduce parking requirements.
315
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 49  Bicycle Parking: Bicycle parking for multi-family and mixed-use development is required.

Table B-8 summarizes parking requirements by residential development type.

Table B-8: Parking Requirements
Residential Land Use Parking Required
Single-Family Dwelling
Standard lot
Substandard lot
Severely substandard lot

2 garage spaces/unit
1 garage space and 1 covered space/unit
1 garage space and 1 uncovered space/unit
Accessory Dwelling Units
Outside coastal access parking restricted area
Inside coastal access parking restricted area

No parking required
1 space in addition to the parking required for
the primary unit
Duplex/Triplex 2 garage spaces/unit; 1 guest space
Manufactured Homes 2 spaces/unit
Multi-Family
Outside the C-D Zoning District

Inside the C-D Zoning District

2 garage spaces/ 2+ bedroom unit; 0.25 guest
spaces/unit

1 space/studio and 1-bedroom units

1.5 spaces/2-bedroom units and larger

0.25 guest spaces/unit
Guest parking waiver for qualifying projects
Mixed-Use (residential portion only)
Outside the C-D Zoning District

Inside the C-D Zoning District

2 garage spaces/ 2+ bedroom unit; 0.25 guest
spaces/unit

1 space/studio and 1-bedroom units

1.5 spaces/2-bedroom units and larger

0.25 guest spaces/unit
Guest parking waiver for qualifying projects
20% reduction for qualifying projects
Source: City of Half Moon Bay Zoning Ordinance 18.36
Program 1-2 directs the updating of these parking standards, including the elimination of requirement for garages for multiplexes, multifamily residential, and mixed-use residential units while considering incentives for garages in developments where space is available.

Mixed-Use Districts: In 2020, the City adopted the “Mixed-Use Districts and Parking Standards Ordinance,” which was subsequently certified by the Coastal Commission later that year. This ordinance reduced many barriers to the development of housing, especially in the CommercialDowntown (C-D) zoning district which covers a significant portion of Downtown Half Moon Bay. 316
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 50 As noted in the table above, the parking standards in the C-D zoning district are lower for units in multi-family and mixed-use development, and those reductions were established in this ordinance. A guest parking waiver further eases the requirements; and a 20% “mixed-use shareduse reduction” bolsters mixed-use development. The impact of the ordinance update was immediate with two projects coming forward on lots located within the heart of Downtown that had stood vacant for many years. Both developers indicated that the updated parking standards made the projects feasible. At the time of the Housing Element drafting, one of the projects was under construction and the other was undergoing plan check review of its pending building permit.

In that the updated parking provisions for the C-D zoning district have worked well, the City intends to allow similar reductions to the Commercial-General (C-G) and Commercial-Residential (C-R) zoning districts, as acknowledged in Program 1-2. It is noted that the City’s other mixed-use district, the Commercial-Visitor Serving (C-VS) zone, is limited in area and its purpose is directly related to the Coastal Act with a focus on coastal access and recreation. The C-VS district does not allow for a significant number of housing units, thus the parking regulations will not be proposed for those areas. This kind of deference to Coastal Act sensitivities has helped the City achieve certification of housing friendly policies by the Coastal Commission. The emphasis on the C-D, C-G, and C-R districts, where several of the inventory sites are located, targets the City’s mixed-use districts with the most potential for housing development. No housing inventory sites are in the C-VS zone.

Residential Zoning Districts: Parking for missing middle units in the residential zoning districts is a more significant constraint. Duplex, triplex, and multifamily units in R-2 and R-3 zoning districts must provide 2 garage spaces per unit (regardless of bedroom count), plus a minimum of one guest parking space. This is especially onerous with small infill sites where parking dictates site planning and consumes the allowable floor area.

Although the City has granted exceptions in cases demonstrating hardship and meeting findings, the current provisions are barriers to developing these types of units, which if not specifically deed restricted as affordable, are at least affordable by design. If a duplex, triples, or multi-family project cannot demonstrate a hardship or is not an affordable project, the requirements for studio and one-bedroom units may constrain development of market rate one and two-bedroom units, as the parking requirement would have the effect of reducing the area of the project site that can be developed and thus indirectly increase the cost of development. For studio and onebedroom units, this may also present an increased burden, as the households occupying these unit sizes are smaller than households occupying larger units. These smaller households likely do not need 2 parking spaces, and the cost to the development project to provide this parking is unnecessary. Programs 1-2 and 1-6 will reduce impacts of the City’s parking requirements on missing middle housing.

On-Site and Off-Site Improvements
317
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 51 For infill sites, improvements include providing access to the site, clearing and grading the site, installing drainage improvements, and frontage improvements. On-site drainage improvements typically include detention basins or bioswales. Frontage improvements typically include curbs, gutters, and sidewalks. Such requirements are typical requirements in other most California cities and do not impose a significant constraint on the development of housing. These improvements can add substantial expense to a housing development, albeit these costs pale in comparison to land acquisition costs (see “Land and Construction Costs” under the Non-Governmental Constraints section). Subdivision-level improvements, which are described in detail in the Local Coastal Land Use Plan, are necessary to achieve health and safety requirements due to Half Moon Bay’s unique coastal geography.

In the case of a subdivision, improvements may also include roads, as well as wet and dry utilities.

Subdivisions are also required to provide parkland or contribute in lieu fees per the Quimby Act.

As with land costs, improvements required are described in Section 17.42 of the Municipal Code.

Section 17.42.050 lists the improvements to be installed by subdividers:

On-Site Improvements:

A. Streets, curbs, gutters, sidewalks, and walkways as may be shown on the parcel map or tentative map as approved by the planning commission and/or city council.

B. Coastal accessways and signs if required where an easement offered for dedication has been or is reasonably expected to be accepted by one of the entities listed in the local coastal plan, the general plan or any of its elements, the city municipal code, or any specific plan. All vehicular accessways to coastal resources on state property shall be constructed to the standards of the State Parks and Recreation Department and the city of Half Moon Bay.

C. Water lines to serve each lot and stubbed to property line prior to paving. A “W” shall be stamped or otherwise permanently marked on the curb to identify stub locations.

D. Sanitary sewers and laterals to serve each lot and stubbed to property line prior to paving. An “S” shall be stamped or otherwise permanently marked on the curb to identify stub location.

E. Fire hydrants of a type and size approved by the Half Moon Bay fire protection district. Fire flows shall be as approved by the fire district.

G. Storm sewers, drains and channel improvements.

H. Silt basins or other forms of erosion control when necessary.

I. Ornamental and safety street lights as required by this title and the city engineer.

J. Unless otherwise approved by the planning commission and/or city council, street trees shall be installed to the following standards:

1. Not less than one tree per lot with an average spacing of fifty feet on center; 318
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 52

2. The type, size and location shall be approved by the city engineer and indicated on the final map;

3. Said trees shall be maintained by the developer for a period of one year, to the satisfaction of the city engineer.

K. Street signs at all block number changes and at locations approved by the city engineer.

L. Street end barricades, walls or facing where required by the city engineer.

M. Stop or yield signs where street intersects with a major street or at other locations required by the city engineer.

N. Utility distribution lines, including but not limited to electric, communications, street lighting and cable television shall be required to be placed underground. The subdivider is responsible for complying with the requirements of this title, and he shall make the necessary arrangements with the utility companies for the installation of such facilities. Minor exceptions to this section may be granted by the city engineer only when requested by the serving utility.

Off-Site Improvements (only required if determined necessary by city engineer and required by the planning commission and/or city council as conditions of subdivision approval):

A. The subdivider shall pay the fee estimated by the Coastside County Water District for the improvement of any existing source of water supply of the water district and the construction of transmission lines from that supply to the proposed development.

B. The subdivider shall pay the fee estimated by the city for the development of sewage disposal facilities or for the improvement of any existing sewage disposal system and the construction of transmission lines from the proposed improvements to the site of disposal.

C. When flood zones or other lawful special purpose zones are established by the city council, the subdivider shall pay the fee set out for the particular zone in which the subject land lies.

D. Properly graded, drained and paved or otherwise improved access roads as may be required by the city engineer.

E. The extension of any other utilities.

Several variables affect the cost of these improvements, including site topography and proximity to established roads, sewers, and water lines. Engineering and other technical assistance costs are usually included with site improvement costs, as these services are required to ensure that development is constructed according to established codes and standards. Off-site 319
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 53 improvements may be required if a project creates significant impacts that require mitigation.

This is determined on a project-by-project basis.

There are the well-documented environmental concerns of greenfield subdivision expansion, including not only development in fire hazard or flood hazard areas but also the second-order issues of increased emissions due to extended commutes. Therefore, Half Moon Bay’s housing strategy concentrates development in areas that have existing infrastructure.

Very high fire severity zones are mapped along the eastern edge of the city limits. Some extend into the city, and within these areas, special construction and long-term commitments to fuel load management are required. None of the Cycle 6 Housing Opportunity sites are within a very high fire severity zone; however, two sites abut this zone and fuel load management along the borders of these properties has been considered in the site inventory and is not a constraint in either case. The LCLUP update ensured that residential densities and safety in fire hazard zones were appropriate for each circumstance and that adequate sites for Cycle 6 RHNA were available outside these areas.

The site inventory emphasizes sites that are within the City’s Town Center where infrastructure is most readily available. The City’s on and off-site improvement requirements are typical and have not been found to pose a barrier to housing development. Site #12, which has already been subdivided and was the subject of litigation, is the only greenfield site in the site inventory. This site is for above-moderate income housing.

Short-Term Vacation Rentals
Broadly, the short-term vacation rental market has grown considerably in the past fifteen to twenty years, especially in popular tourist destinations. Half Moon Bay offers numerous coastaloriented activities and attractions for visitors, and local short-term vacation rental growth has been steadily increasing throughout the city.

The City has been concerned about the loss of housing stock to full-time short-term rental use and initiated a public process to develop short-term rental regulations in 2018. Draft code was nearing completion in early 2020, but had to be set aside while the City’s small staff turned their attention to community needs and challenges imposed by the COVID pandemic. The ordinance was picked back up in early 2021; and after numerous study sessions and hearings, the City Council adopted it in September of that year. The ordinance was submitted to the California Coastal Commission for certification at the end of 2021. The Coastal Commission certification process involved a time extension action, followed by two public hearings, and finally concluded with conditional certification in March 2023. To establish a new short-term vacation rental, the ordinance requires primary residency of the dwelling unit and imposes a 60-night maximum for un-hosted operations. The ordinance also disallows short-term rental operations out of mobile homes, deed restricted affordable housing units, ADUs, and most multi-family housing units. The City established these provisions with the specific intent to protect against further erosion of housing stock to short-term rental use.
320
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 54 The City understands that this is one of the most restrictive and conservative short-term rental ordinances that the Coastal Commission has ever certified. After significant effort providing data and extensive analysis, the City was able to successfully demonstrate that without a primary residence requirement, continued loss of housing stock to short-term rental use was reasonably foreseeable and would likely become cumulatively significant over time. The Coastal Commission in its deliberations, also viewed the ordinance through the lens of its 2019 environmental justice policy which had increased the Commission’s sensitivity to housing concerns, as well as the City’s LCLUP policies presented earlier in this technical report. Because the Coastal Commission certified the ordinance with modifications from the City Council’s language, the City will need to readopt the ordinance per the Commission’s action. This will take two noticed public hearings.

Following that, the Coastal Commission will need to confirm the City’s readoption as consistent with the Coastal Commission’s conditional certification action in March 2023.

Once all the adoption actions described above are completed, the Short-Term Rental Ordinance will become part of the City’s Zoning Ordinance, which is a major component of the LCP’s IP. This ordinance adoption process is an illustrative example of the timelines and logistics involved to accomplish Zoning Ordinance amendments in the Coastal Zone. Despite the fact that this one worked out well from the City’s perspective, it took a significant amount of time and required repeated efforts by City staff to produce additional data and analysis to support the Coastal Commission’s review. Thus, even with good outcomes, zoning amendments need to be acknowledged as a continued constraint for Half Moon Bay.

Water and Sewer Priority
Water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households, per Government Code § 65589.7. The City’s Below Market Rate Ordinance references this requirement (Zoning Code 18.35.050(2)), but the City also requires a requirement beyond units developed through that ordinance.

Program 6-5 directs the City to deliver the housing element to the Coastside County Water District and Sewer Authority Mid-Coastside immediately after certification and to establish a written procedure to prioritize water and sewer service to such developments by the end of June 2026.

Permit Processing Procedures, Timelines, and Fees
The residential development process has various stages, each of which requires some form of City approval. Most residential development in Half Moon Bay requires a coastal development permit. Residential subdivisions and multi-family projects, as well as some single-family homes, require design review. Land development in the PUD zoning district requires Coastal Commission certification of a master plan, such as a specific plan or other type of master plan. Additional discretionary entitlements associated with residential development review may include use 321
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 55 permits, variances, and/or parking exceptions. These development review processes are described below.

Preliminary Review:

The City offers a flexible preliminary review process to help applicants prepare complete applications for projects that conform with policy and zoning requirements. The process includes early review by outside districts including Coastside Fire Protection District and CCWD, as well as all City Departments involved in development review. In some cases, preliminary plans are concurrently presented to the Planning Commission in study session format, or the Architectural Advisory Committee (discussed in more detail later in this section), to ensure that this early input is well-coordinated. Numerous developers have taken advantage of preliminary review which does not require an applicant to submit highly detailed or complete plans. City staff have received positive feedback on the process.

Building Permits:

The City adopts the triannual updates to the California Building Code (CBC) and uses it for building plan check review of building permit applications. Local amendments to the CBC include those attributed to the Fire District which imposes additional requirements for sites located within or adjacent to fire hazard areas. Any cost impacts associated with such requirements would be offset by the cost, or even availability of, fire insurance. Until recently, the City’s local amendments primarily addressed grading. In 2022, the City’s local amendments focused on sustainability requirements, similar to a “reach code,” to promote building electrification and the provision of EV-ready parking spaces. Reach Codes are amendments to the Energy and Green Building Standards Codes that will result in reductions in greenhouse gas emissions (GHGs) for existing and new development. Pacific Gas and Electric (PG&E) and Peninsula Clean Energy (PCE) for energy service to the city, and these agencies offer energy conservation programs to residents and businesses that can help offset the cost of installing new or converting existing fuel-gas appliances to electric. City staff is aware of several builders opting for all-electric buildings in advance of the City’s adoption of its reach code provisions which allowed projects to develop without extending natural gas lines.

Code Enforcement:

Generally, the City’s approach to code enforcement is on a complaint basis with the exception of risk of harm to life or property. The City’s Community Preservation Specialist, instead of focusing solely on violations, works to educate and help property owners understand code requirements and their options for abating problems. One example is the City’s preemptive communication to property owners about needed fuel load management in advance of the Fire District’s deadline. In other cases, the City may determine that other community resources are needed, such as temporary use of a dumpster from the solid waste service provide, or small grants to help fund home improvements.

Coastal Development Permits
322
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 56 Because the entire city is located within the Coastal Zone, most development requires a coastal development permit as regulated per Zoning Ordinance Chapter 18.20 (Local Coastal Development Permits). While the City can amend the LCP, which includes the Zoning Ordinance, the California Coastal Commission must certify these actions. Therefore, the City cannot guarantee any reduction or easing of constraints associated with this permitting process.

Broadly, a coastal development permit must be processed for all proposals that meet the definition of “development” (see footnote, page B-31). This definition is relevant to the vertical development of structures (e.g., dwelling units), infrastructures, as well as most subdivisions, including parcel maps and even lot line adjustments. Some exceptions include replacement of structures following disaster, repair, and maintenance of existing structures, modest additions to single-family residences, and other improvements normally associated with single-family residences.

A noticed public hearing is required for most coastal development permits. The body with the final approval authority, the Community Development Director, Planning Commission, or City Council, issues the permit. A coastal development permit may be approved or conditionally approved only after the approving authority has made the following findings (Zoning Ordinance

18.20.070):

A. Local Coastal Program. The development as proposed or as modified by conditions conforms to the local coastal program;
B. Growth Management System. The development is consistent with the annual population limitation system established in the land use plan and zoning ordinance; C. Zoning Provisions. The development is consistent with the use limitations and property development standards of the base district as well as the other requirements of the zoning ordinance;
D. Adequate Services. Evidence has been submitted with the permit application that the proposed development will be provided with adequate services and infrastructure at the time of occupancy in a manner that is consistent with the local coastal program; and E. California Coastal Act. Any development to be located between the sea and the first public road conforms with the public access and public recreation policies of Chapter 3 of the California Coastal Act.

F. Design Review Criteria. (See discussion in next section, “Design Review.”) Conditions of Approval: The permit approving authority may apply conditions of approval as necessary to ensure conformance with and implementation of the LCP. Modification of the project and resubmittal of the plans may be necessary to ensure conformance with the LCP. 323
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 57 Accessory Dwelling Units and Administrative Coastal Development Permits: The City’s Accessory Dwelling Unit Ordinance was certified by the Coastal Commission and submitted to HCD for review in 2022. While State housing law directs that a ministerial review process is required for ADUs, the law also includes a carve out that provides discretion in the Coastal Zone to ensure that ADU development is consistent with the LCP. Before 2018, the City’s Accessory Dwelling Unit Ordinance required a substantial discretionary review process; however, now the code sets forth a process for administrative coastal development permits for “new development” ADUs (e.g., those that involve new construction or conversion of un-conditioned space) which can be reviewed quickly according to objective standards. Also, ADUs involving limited new construction and/or conversion of conditioned space do not require an administrative coastal development permit and can move straight to the building permit stage.

Local Appeals: Coastal development permits are discretionary approvals and the decisions are open to appeal for ten working days following the action. The Community Development Director’s decisions may be appealed to the Planning Commission; the Planning Commission’s decisions may be appealed to the City Council. City Council decisions can also be appealed to the Coastal Commission in some cases, as described below. Appeals may be directed to the decision itself to approve or deny a project or to the conditions of approval.

Coastal Commission Permit and Appeals Jurisdiction: Developments on tidelands, submerged lands, and public trust lands require that the permit be issued by the Coastal Commission. This requirement is not especially relevant to new housing development, but has been required for some existing development that became proximate to the beach due to years of bluff erosion.

However, the Coastal Commission appeals jurisdiction may come into play for numerous residential development sites in the city. For the following development types or locations, the City’s approval of a coastal development permit may be appealed to the Coastal Commission:
 Developments between the sea and the first public road paralleling the sea, or within 300 feet of any beach or the mean high tide line where there is no beach, whichever is the greater distance;
 Developments that are located on tidelands, submerged lands; public trust lands; within 100 feet of any wetland, estuary, or stream; or within 300 feet of the top of the seaward face of any coastal bluff; and
 Any development that constitutes a major public works project or energy facility.

In Half Moon Bay, in addition to the western seafront, numerous creeks, wetlands, and other sensitive habitat areas are found throughout the city. These environmentally sensitive water features result in numerous sites being located within the appeals jurisdiction. Thus, in these areas, the City does not have final land use authority. The City’s decisions may be amended or 324
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 58 revoked through such appeals, often imposing lengthy delays, and resulting in reductions in project size, such as the number of dwelling units.

Before a project can be appealed to the Coastal Commission, all local appeals must be exhausted.

The City does not charge a fee for appeals in the Coastal Commission appeals jurisdiction per Coastal Commission guidance. Challenging a project through an appeal process up to the Coastal Commission is much simpler and less expensive than other means of challenges outside the Coastal Zone, such as by filing a CEQA lawsuit. Thus, the risk of appeals overriding the City’s land use decisions results in significant developer uncertainty. Furthermore, while the City can make efforts to accommodate the RHNA through its site inventory, the Coastal Commission appeals can severely limit the City’s ability to actually accommodate it. Fortunately, most of the City’s Cycle 6 site inventory comes with policy support from the recently certified LCLUP; and many of these sites are not in the appeals jurisdiction. Completion of implementation zoning will further bolster the potential for the site inventory to achieve the City’s intended buildout for these sites to best utilize each site’s capacity.

Design Review
Design review is required for nearly all residential development projects. Half Moon Bay Municipal Code 14.37.020 (Architectural, Landscape and Site Plan Review) specifies various residential types and locations for which design review is required. It covers every type of housing unit other than ADUs and mobile homes:
 New residential units or modifications to an existing unit requiring a discretionary permit including a coastal development permit, variance, use permit, or parking exception.  Modifications to or new residential units affecting a historic resource and/or located within the heritage Downtown area.
 New residential units within a planned unit development.  Any multiple-family residential structure with more than two units on a single building site, and for additions, significant exterior alterations or improvements to any multifamily structure and/or site.

The design review process considers the character and quality of design; compatibility with neighboring properties; development characteristics of the project, including building coverage and use of open space; building materials and colors; disturbance of topography, trees, and other natural features; accessory structures; exterior building features; and energy efficiency and renewable energy design elements. Design approval criteria is presented in Municipal Code, section 14.37.035, as follows:

A. Where more than one building or structure will be constructed, the architectural features and landscaping thereof shall be harmonious. Such features include height, elevations, roofs, material, color and appurtenances.
325
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 59 B. Where more than one sign will be erected or displayed on the site, the signs shall have a common or compatible design and locational positions and shall be harmonious in appearance.

C. The material, textures, colors and details of construction shall be an appropriate expression of its design concept and function, and shall be compatible with the adjacent and neighboring structures and functions. Colors of wall and roofing materials shall blend with the natural landscape and be nonreflective.

D. The design shall be appropriate to the function of the project and express the project’s identity.

E. The planning and siting of the various functions and buildings on the site shall create an internal sense of order and provide a desirable environment for occupants, visitors and the general community.

F. Roofing materials shall be wood shingles, wood shakes, tile or other materials such as composition as approved by the appropriate design review authority. No mechanical equipment shall be located upon a roof unless it is appropriately screened.

G. The proposed development shall be compatible in terms of height, bulk and design with other structures and environment in the immediate area.

H. The proposed design shall be consistent with the applicable elements of the general plan.

I. If the project site is located in an area considered by the appropriate design review authority as having a unified design character or historical character, the design shall be compatible with such character.

J. The design shall promote harmonious transition in scale and character in areas located between different designated land uses.

K. The design shall be compatible with known and approved improvements and/or future construction, both on and off the site.

L. Sufficient ancillary functions provided to support the main functions of the project shall be compatible with the project’s design concept. The planning and siting of ancillary functions shall address utilities, drainage facilities, lighting, trash and recycling provisions, and other matters applicable to the project site and use.

M. Access to the property and circulation systems shall be safe and convenient for equestrians, pedestrians, cyclists and vehicles.

N. The amount and arrangement of open space and landscaping shall be appropriate to the design and the function of the structures.

O. Landscaping shall be in keeping with the character or design of the building, and preferably clustered in natural appearing groups, as opposed to being placed in rows or regularly spaced.

P. Where feasible, natural features shall be appropriately preserved and integrated into the project.

Q. The landscape design concept for the site, as shown by the relationship of plant masses, open space, scale, plant forms and foliage textures and colors, shall create a desirable and 326
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 60 functional environment and the landscape concept shall depict an appropriate unity with the various buildings on the site.

R. Plant material shall be suitable and adaptable to the site, shall be capable of being properly maintained on the site, and shall be of a variety which would tend to be drought-resistant and to reduce consumption of water in its installation and maintenance.

S. The design shall be energy efficient and incorporate renewable energy design elements including, but not limited to:
(i) Exterior energy design elements;
(ii) Internal lighting service and climatic control systems; and (iii) Building siting and landscape elements.

The permit review authority is responsible for design review, including the Community Development Director, Planning Commission, or City Council. During Cycle 5, the City reestablished an Architectural Advisory Committee to streamline the design review process. The Committee is a recommending body to the permit review authority. The City integrates design review into consideration or preliminary applications, during periods when biological resource evaluation work is ongoing, and in other ways so that it is conducted as a parallel process and does not lengthen review timelines. The Committee is small and comprised of an architect, a landscape architect, and a contractor. These experienced professionals collaborate with applicants and have provided valuable guidance to improve livability, sustainability, and the durability of proposed development. Notably, Half Moon Bay’s coastal setting imposes a harsh environment on the built environment. Care in the selection of materials and how they are assembled requires care, and the local Architectural Advisory Committee members have helped many applicants make better design choices that will save on maintenance expenses in future years.

These findings as currently written are not objective and do not allow for approval certainty.

Specifically, A through E, G, I through O, and Q are subjective. Program 1-2 directs the City to rewrite design review findings to be objective by 2025.

The design review process does not regulate any specific uses, but requires all uses to comply with specific design standards. The City’s design review requirements are clearly established in the Zoning Ordinance and are written to allow flexibility in achieving substantial compliance.

Design review has not added significant time or expense to the entitlement process, which is especially so in recent years now that the Architectural Advisory Committee’s review process is integrated into the development review process.

Planned Unit Development Master Plans
The Planned Unit Development (PUD) district implements the Planned Development (PD) land use designation. It is intended to avoid piecemeal development and provide flexibility required for the achievement of coastal, environmental, and safety goals. While the LCLUP policies guide each substantially undeveloped PUD district, the specific development standards, allowed uses, and development densities established for the PUD district must be established through master planning. Master plans may be implemented through Specific Plans or other types of planning 327
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 61 tools. Findings for a PUD’s master plan must identify, per Sections 18.15.030 through 18.15.065 of the Zoning Code, that the PUD is compatible with surrounding uses, will result in superior design and development of the site, is consistent with the LCLUP and General Plan and all applicable policies and ordinances, provides for phasing of development to ensure that the capacity of public services and infrastructure is not exceeded, and that mitigation measures are incorporated to mitigate any potential adverse impacts.

The PUD district is intended to provide for a variety of land uses, such as attached and detached single-family residential development, multifamily housing development, professional and administrative areas, commercial and industrial uses, institutional uses, and public and private open space and recreation opportunities through the adoption of a comprehensive development plan as set forth in the LCLUP and Zoning Code.

A planned unit development plan must include a detailed description of the proposed uses, densities, and intensities; figures illustrating the site plan, circulation plan, project relationship with adjacent uses, environmental constraints, building elevations, preliminary landscaping, and preliminary grading plans; description of proposed development standards; and description of necessary on- and off-site improvements.

For a planned unit development to be recommended by the Planning Commission and approved by the City Council, the following findings must be made (Zoning Ordinance 18.15.040 Planned Development Land Use, Required Findings of Fact):

A. The planned unit development plan is consistent with the adopted general plan, Chapter

18.15 of the Zoning Code, and all other applicable policies and ordinances of the city; B. The planned unit development plan is compatible with surrounding land uses; C. The adoption and implementation of the planned unit development plan will result in superior design and development of the site;
D. The planned unit development plan meets the requirements of any annual dwelling unit allocation system adopted by the city;
E. Adoption and implementation of the planned unit development plan will not exceed the capacity of existing or planned infrastructure systems, including but not limited to sewer, water, natural gas, electricity, and police and fire protection; F. If adequate utilities, infrastructure, and public services are not available to serve all of the proposed development possible under the planned unit development plan, the plan contains phasing controls or requirements for utility improvements that ensure that demands from proposed development does not exceed utility capacity; and 328
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 62 G. The applicant, or Planning Commission and City Council, have incorporated all appropriate measures and conditions in the planned unit development plan necessary to mitigate any potential adverse impacts identified during the public review process.

Following City Council approval, PUD plans are subject to Coastal Commission certification, similar to zoning amendments. Approval of development within an approved PUD area requires a use permit.

SB 35
SB 35 (2017) requires jurisdictions to develop a streamlined ministerial approval process under certain circumstances. Half Moon Bay has not currently met their prorated Lower and Above Moderate Income Regional Housing Needs and is subject to SB 35.

However, all of Half Moon Bay is located in the Coastal Zone and SB 35 does not apply to developments that are located in the coastal zone and have the following restrictions (see:

Government Code 65913.4(a)(6):
i. Subject to paragraph (1) or (2) of subdivision (a) of Section 30603 of the Public Resources Code (meaning: (1) developments between the sea and the first public road paralleling the sea or within 300 feet of the inland extent of any beach or of the mean high tideline of the sea where there is no beach, whichever is the greater distance or (2) developments approved by the local government not included within paragraph (1) that are located on tidelands, submerged lands, public trust lands, within 100 feet of any wetland, estuary, or stream, or within 300 feet of the top of the seaward face of any coastal bluff.
ii. An area of the coastal zone that is not subject to a certified local coastal program or a certified land use plan.
iii. An area of the coastal zone that is vulnerable to five feet of sea level rise, as determined by the National Oceanic and Atmospheric Administration, the Ocean Protection Council, the United States Geological Survey, the University of California, or a local government’s coastal hazards vulnerability assessment.
iv. In a parcel within the coastal zone that is not zoned for multifamily housing. v. In a parcel in the coastal zone and located on either of the following:
o (I) On, or within a 100-foot radius of, a wetland, as defined in Section 30121 of the Public Resources Code.
o (II) On prime agricultural land, as defined in Sections 30113 and 30241 of the Public Resources Code.

Half Moon Bay will develop an SB 35 ordinance per Program 1-11 that will apply to parcels not precluded by Government Code 65913.4(a)(6) and in case of a change of law.

Other Discretionary Planning Permits: Use Permits, Variances, and Parking Exceptions 329
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 63 Sometimes coastal development permits are processed with accompanying permits in a parallel process. These primarily include use permits, variances, and parking exceptions. The City has tried to simplify and/or reduce these requirements as a means to reduce the timing and cost of discretionary permit review. The Mixed-Use Districts and Parking Standards Ordinance, discussed above in the “Parking” section, addressed this directly by eliminating the requirement for a use permit for multi-family or mixed-use development in the C-D, C-R, and C-G mixed-use zoning districts. The same ordinance, which reduced parking requirements as previously described, also established simplified findings for parking exceptions. These improvements during Cycle 5 were notable accomplishments for reducing constraints imposed by the permit process.

Processing Times
Initial processing of a development application depends on the type of project proposed (e.g., Planned Unit Development, subdivision, single-family unit, etc.) as well as whether additional requirements will need to be met (e.g., rezoning of land, environmental review, etc.). Therefore, processing review times can vary depending on many different factors. Table B-8 identifies the average and 75th percentile application processing times for jurisdictions in San Mateo County.

The processing time required by the City for straightforward applications, such as applications for ministerial review, design review, and use permits is generally close to the county average for straightforward applications. The time to process more complicated projects, including those that require a coastal development permit, is closer to the countywide 75th percentile associated with complicated applications.

330
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 64 Table B-9: San Mateo County Permit Processing Times (in months)

ADU
Process
Ministerial
By-Right
Discretionary
By-Right
Discretionary
(Hearing
Officer if
Applicable)
Discretionary
(Planning
Commission)
Discretionary
(City Council)
Atherton 1 to 2 1 to 3 2 to 4 N/A 2 to 4 2 to 6
Brisbane 1 to 2 2 to 6 N/A N/A 4 to 12 6 to 14
Burlingame 1 to 2 2 to 3 2 to 3 N/A 3-4 standard
projects; 12
major
projects
13 months
Colma 1 to 2 1 to 2 1 to 3 2 to 4 N/A 4 to 8
Daly City 1 to 2 2 to 4 N/A N/A 4 to 8 8 to 12
East Palo Alto 1 to 3 8 to 12 6 to 14 20 to 40 20 to 40 20 to 40 Foster City 1 to 2 1 to 2 1 to 2 3 to 6 6 to 12
Half Moon Bay 1 to 2 2 to 4 3 to 6 4 to 12 6 to 15
Hillsborough - - - - - -
Millbrae 0 to 2 3 to 6 1 to 3 3 to 8 3 to 8 4 to 9
Pacifica 1 to 2 2 to 3 4 to 5 5 to 6 5 to 6 7 to 8
Redwood City 2 to 3 3 to 4 N/A 8 to 10 12 to 18 18 to 24 San Bruno 2 3 to 6 N/A 3 to 6 9 to 24 9 to 24
San Mateo 4 to 8 1 to 2 4 to 7 N/A 9 to 12 9 to 13
South San
Francisco
1 1 2 to 3 2 to 3 3 to 6 6 to 9
Unincorporated
San Mateo
1 to 3 3 to 6 4 to 9 6 to 12 6 to 18 9 to 24
Woodside 1 to 2 1 to 2 N/A N/A 2 to 6 3 to 8
Source: 21 Elements Survey, 2022
Longer processing times occur for a variety of reasons, mostly related to the Coastal Zone context. For example, many project sites, due to the proximity of known and mapped, or apparent potential ESHA, are subject to preparation of a biological resources evaluation (BRE) early in the review process. BREs must be circulated for 45 days to relevant resource agencies including the California Coastal Commission, the Regional Water Quality Control Board, the State Department of Fish and Wildlife, and others. Agency review often indicates that special conditions may need to be addressed for a project site, such as the need to prepare wetland delineations and/or provide habitat buffers which can affect the footprint of development. While the preparation of a BRE is a special process step, by completing this early in project review, developers and the City can work out ways to manage special conditions related to ESHA before any CEQA document is completed and public hearings. Thus, the BRE requirement is meant to simplify and bring about projects that are approvable from the perspective of abiding by resource projection requirements. In addition to the BRE process, a notable delay outside of the City’s 331
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 65 processing timeline is obtaining Coastal Commission approvals on appeals and permits that are subject to the Commission’s purview. It is not atypical for larger developments in Half Moon Bay to be appealed and/or litigated, adding significant delays outside of the City’s control.

The processing times presented in Table B-9 are for single-family and multi-family projects that do not require a zone change or LCLUP/General Plan amendment. The City’s processing times are typically within the 75th percentile of jurisdictions within the county. While typical processing times are above the county average and can be considered a constraint, this is primarily due to the city’s location in the Coastal Zone and the requirements of the Coastal Act. The requirements of the Coastal Act and related processing times are codified by State law and are outside of the control of the City.

Table B-10: Typical Processing Procedures and Timelines by Project Type Project Type:

Coastal
Development
Permit
Design
Review Typical CEQA Subdivision
Map
Estimated
Process
Time
(weeks)*
Single Family
Home 
If visual
resources
area
Sometimes, if in
coastal
resources area
N/A 18-52
Single Family
Subdivision
 
Initial Study to
determine
exemption; or
Negative
Declaration
Tentative Map
&
Final Map;
Subdivision
Agreement
52-64
Multi-Family
or Mixed-Use
Development  
Initial Study to
determine
exemption; or
Negative
Declaration
N/A 26-52
Source: City of Half Moon Bay
*Estimated time is longer for projects that are not exempt from CEQA; especially if biological resources are present which may require multiple field investigations in different seasons.

Governmental Fees
The City charges flat fees for some planning permits, such as administrative coastal development permits for ADUs. Other planning permits are subject to deposit-based cost recovery whereby the City’s planning, building, and engineering staff log time spent processing an application. Any remaining deposit funds are returned to applicants when project review is complete. All building permits are subject to flat fees scaled to project valuation. The City’s Master Fee Schedule includes flat fees and deposit rates. The fee schedule is posted on the City’s website in multiple locations intended to be convenient for property owners, developers, and contractors. 332
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 66 The 21 Elements project surveyed the cities of San Mateo County to determine development fees, including planning, building, and impact fees.7 The 21 Elements group provided basic assumptions for the hypothetical projects (see the footnotes of Table B-10 so that the fees could be compared across jurisdictions.

In Half Moon Bay, fees for a single-family residence total approximately $40,000 for a singlefamily home and $25,000 for each multi-unit home in multi-family development (e.g., 10 units).

These fees assume that the project site is a participant in the City’s sewer assessment district; higher fees presented in the table, of about $15,000 per unit, apply to project sites outside the district. The 21 Elements assumptions for a large multi-family development were for a 100-unit multifamily project, which is not a pertinent form of development for Half Moon Bay.

The City’s estimated fees per unit include development impact fees in effect in the fiscal year 2021-22:

Table B-11: Total Fees Per Unit
Single-Family Small Multi-Unit
Sewer Capacity (two
options)
• District Participation $5,272 $,4,28
• Non-Participant $18,743 $18,743
Storm Drainage $803 $317
Capital Outlay Facilities $1,138 $949
Traffic Mitigation $7,417 $4,045
Park Facilities $8,375 $7,4,32
In addition, there are fees per project – not all of which are necessarily applicable to every project – such as:
• Building Permit: $823 - $5,281, depending on square footage of project • Building Plan Check Fee: $181/hour
• General Plan Amendment: $17,693
• Conditional Use Permit: $1,139
• Variance: $1,139
• Coastal Development Permit Processing: $2,519 - $6,232, depending on # of units These fees are roughly in line with neighboring jurisdictions in San Mateo County, as shown in Table B-12.

7 The fees presented for Half Moon Bay do not include water connections. Water connections are discussed in the Infrastructure section of this technical report.
333
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 67 Table B-12: Total Fees Per Unit
Single-Family Small Multi-Unit Large Multi-Unit
Atherton $15,941 No Data No Data
Brisbane $24,940 $11,678 No Data
Burlingame $69,425 $30,345 $23,229
Colma $6,760 $167,210 $16,795
Daly City $24,202 $32,558 $12,271
East Palo Alto $104,241 No Data $28,699
Foster City $67,886 $47,179 $11,288
Half Moon Bay $39,892 or $54,238 $25,194 or $40,439 N/A Hillsborough $71,092 No Data No Data
Millbrae $97,756 $6,824 $55,186
Pacifica $33,725 $40,151 No Data
Portola Valley $52,923 No Data No Data
Redwood City $20,795 $18,537 $62,696
San Bruno $58,209 $72,148 $39,412
San Mateo $99,003 $133,658 $44,907
South San Francisco $81,366 $76,156 $32,471
Unincorporated San Mateo $36,429 $27,978 $10,012
Woodside $70,957 $82,764 No Data
Source: 21 Elements Survey, 2022
Notes: Half Moon Bay: Does not include water connections or school impact fees. Two fees presented with the lower fee for project sites within the sewer assessment district; and the higher fee per unit for project sites outside the sewer assessment district.

All other jurisdictions: Includes entitlements, building permits, and impact fees as reported by other jurisdictions.

Governmental permit and impact fees range from 2 – 5% depending on unit type and sewer district participation. In addition to the significant range in price of sewer capacity fees, the traffic mitigation and park facilities fees are also of note, totaling over $15,000 for a single-family home, and over $11,000 for each unit in a multi-unit development. The City has not seen these fees impact development interest in single-family homes. However, for multi-family, staff has engaged with several property owners/developers who expressed concern and are interested in qualifying for fee reductions, specifically for projects that include affordable units. Such fee reductions and an associated affordable housing agreement would require City Council approval.

In all cases, this represents a small percentage of the overall development cost as presented in Table B-13.

334
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 68 Table B-13: Total Fees as a Percentage of Total Development Costs Single-Family Small Multi-Family Large Multi-Family
Atherton 0% No Data No Data
Brisbane 1% 1% No Data
Burlingame 3% 4% 3%
Colma 0% 17% 2%
Daly City 1% 4% 2%
East Palo Alto 4% No Data 4%
Foster City 3% 6% 2%
Half Moon Bay 2% – 3% 3% - 5% N/A
Hillsborough 3% No Data No Data
Millbrae 2% 8% 7%
Pacifica 1% 5% No Data
Portola Valley 1% No Data No Data
Redwood City 1% 2% 8%
San Bruno 2% 8% 5%
San Mateo 4% 14% 6%
South San Francisco 3% 9% 4%
Unincorporated San Mateo 1% 3% 1%
Woodside 2% 9% No Data
Source: 21 Elements Survey, 2022
Notes: The above table is calculated using average soft costs (including an average of jurisdiction charged fees) and average land costs for the county. A more precise determination of fees as a percentage of total development costs can be calculated using jurisdiction specific land costs and fees.

Half Moon Bay: The lower percentage is for project sites within the sewer assessment district; and the higher percentage is for project sites outside the sewer assessment district.

Half Moon Bay’s Master Fee Schedule through Fiscal Year 2023-2024 is available at https://www.half-moon-bay.ca.us/378/Master-Fee-Schedule.

Water connection fees are not accounted for in Table B-12 or B-13. These fees can significantly impact development cost and are explained in more detail later in the Infrastructure section of this report. The cost of water connections would increase fees for market rate single-family units by an estimated $90,000 per unit; thereby increasing the percentage of fees for total development cost to about 7%. Similarly, for market rate multi-family development, assuming that one-half a water connection is needed per unit, the cost of water connections would increase fees per unit by an estimated $45,000; thereby increasing the percentage of fees for total development cost to about 10%. In the case of affordable housing, units qualifying for water connections specifically reserved for units affordable to low- and lower-income households, the cost of water connections would increase fees by about $8,000 per unit; thereby increasing the percentage of fees for total development cost much more modestly, to between 4% and 6%. This illustrates the critical importance of water connections reserved for affordable housing, which is acknowledged throughout the Cycle 6 Housing Element for Half Moon Bay. 335
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 69 Fees Transparency
Half Moon Bay currently posts fees on the City website, half-moon-bay.ca.us. Program 6-4 will direct the City to comply with new transparency requirements and post all zoning and development standards as well.

NON-GOVERNMENTAL CONSTRAINTS
Government Code 65583(a)(6) also requires a review of local efforts to remove nongovernmental constraints that create a gap in the jurisdiction’s ability to meet RHNA by income category. Nongovernmental constraints are primarily market driven and, in many circumstances, outside of a local government’s ability to directly control. These constraints may include land costs, the cost of construction, financing, and availability of housing. State law calls for the City’s Housing Element to contain a general assessment of these non-governmental constraints, which can serve as the basis for actions that local government may pursue to offset their effects.

Land and Construction Costs
Land costs in San Mateo County have steadily continued to rise, due in part to the desirability of housing in the region and the short supply of developable land for housing. These costs vary both between and within jurisdictions based on factors like the desirability of the location and the permitted density. According to data from Century Urban, a typical multi-family construction in San Mateo County, land costs add approximately $100,000 per unit. For a single-family home, the average land cost is $514,455 or more per lot.

Construction costs include both hard costs, such as labor and materials, and soft costs, such as architectural and engineering services, development fees, and insurance. For multi-family homes in San Mateo County, hard costs account of 60 to 65% of the building cost, and soft costs average around 15 to 20% (the remaining 15 to 20% is land costs). For single-family homes, hard costs often are roughly 40% of the total cost, soft costs are 20%, and land is 40%.

Hard costs are around $420 per square foot for the smaller single-family residential prototype, and assuming higher finishes, $525 for the larger single-family homes. The hard costs for multifamily construction (both a 10-unit and 100-unit development) were $522 for the smaller multifamily prototype and $517 for the larger multifamily prototype.

According to data from Century Urban, the total development cost in San Mateo County for a single-family home of 2,600 square feet is $2,487,000, averaging $949 per square foot. The total development cost for a 5,000-square foot single-family home is $4,430,000, averaging $848 per square foot.

According to housing developers in San Mateo County, construction costs for multi-unit buildings vary based on the form of parking (structured vs. surface) in addition to other environmental factors such as topography, pre-existing structures, etc. According to the research by Century Urban conducted on behalf of the San Mateo County 21-Elements collaborative, the total 336
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 70 development cost of a small (10,000 square foot/10-unit) multi-family unit is $786,000, and the total development cost of a large (93,750 square foot/100 unit) multi-family unit is $732,500.

Mortgage Financing
One of the most significant factors related to the provision of adequate housing for all segments of the population is the availability of financing. Even small changes in the interest rate for home purchases can dramatically affect affordability. For example, a 30-year home loan for $400,000 at 5% interest has monthly payments of roughly $2,150 while a similar home loan at 7% interest has payments of roughly 20% more, or $2,660.

Table B-14 shows the average annual mortgage interest rates for the United States in the years 2011 to 2021. As shown, interest rates were at a historic low, and dropped even further during the Covid-19 pandemic in 2020. However, interest rates in 2022 are on the rise making mortgages increasingly more expensive.

Table B-14: Average Annual Interest Rates from 2012 to 2022 Year Annual Average
Rate (%)
2011 4.45
2012 3.66
2013 3.98
2014 4.17
2015 3.85
2016 3.65
2017 3.99
2018 4.54
2019 3.94
2020 3.11
2021 2.96
Source: Freddie Mac, Monthly Average Commitment Rate and Points on 30-Year Fixed-Rate Mortgages San Mateo County qualifies as a high-cost area for the Federal Housing Administration (FHA) loan program, and can be provided a higher loan limit. In 2021, prospective home buyers could receive a loan of up to $822,000 for a single-family home and approximately $1,582,000 for a four-plex through an FHA loan.

Construction Financing
Between late-2021 and continuing into 2022, a combination of inflation and interest rate increases have resulted in higher costs to develop housing. The Bureau of Labor Statistics publishes the Consumer Price Index (CPI) and Producer Price Index (PPI), both of which have shown higher than average increases. Mortgage and construction loan rates have similarly risen 337
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 71 adding to an already constrained cost to build housing. The City can circumvent some aspects of escalating housing development expenses by utilizing City-owned land for the exclusive use of producing affordable housing. Local affordable housing developers shared that the use of Cityowned land may need to be paired with a variety of financial subsidies to reach project feasibility.

Affordable housing developers often need to leverage multiple funding sources, tax credit incentives, and to reach a specific density of units.

Labor Costs (Prevailing Wage & Davis Bacon Act)
The California Labor Code applies prevailing wage rates to affordable housing and public works projects. Public works projects include construction, alteration, installation, demolition, or repair work performed under contract and paid for in whole or in part out of public funds. Prevailing wage rates for San Mateo County are established and updated annually by the state’s Director of Industrial Relations. Furthermore, if federal funds are involved, Davis-Bacon Act wages often apply. Under the Davis-Bacon Act, workers must be paid no less than the locally prevailing wages, as well as overtime payments of time and a half. While the cost differential in prevailing and standard wages varies based on the skill level of the occupation, prevailing wages tend to add to the overall cost of development even as they help ensure that laborers are being paid a fair wage.

In the case of affordable housing projects, prevailing wage requirements have the potential impact of increasing project costs and acting as a constraint on development. This can also impose a significant cost impact on rehabilitation of affordable housing units for low- or moderate-income persons and the infrastructure to support such housing. The rehabilitation of certain qualifying affordable housing units for low- or moderate-income persons is exempted from this requirement. SB 972 provides for exemptions from prevailing wage requirements for the construction or rehabilitation of privately-owned residential projects operated on a not-forprofit basis as housing for homeless persons or that provide for housing assistance.

Proximity to Major Job Centers
A large gap between high job growth and limited availability of housing for workers has led to prohibitive cost of living throughout San Mateo County. For example, the County is home to many large employers including Genentech (South San Francisco), YouTube (San Bruno), Meta (Menlo Park), Visa (Foster City), and many healthcare institutions, as well as the San Francisco International Airport being located on the County’s eastern border. Although Half Moon Bay is separated by rural open space from these major job centers, most employers are located 7 to 15 miles from Half Moon Bay, which results in the vast majority of residents traveling outside of the city for work (see Figure B-1 below). According to the U.S. Census American Community Survey, between 2010 and 2019, 102,500 new jobs were created while only 9,494 new housing units were built within San Mateo County, a ratio of 11:1.

Geographically, San Mateo County sits between San Francisco and Santa Clara counties, which are also home to large employment centers within an expanding Bay Area region. The City of Half Moon Bay and San Mateo County cost (often referred to as the Midcoast or Coastside), including the surrounding unincorporated communities from Montara to the north and Pescadero to the south, supply a limited number of jobs to coastal residents. As seen in Table B-15 below, the 338
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 72 Midcoast region, which includes Half Moon Bay and unincorporated coastal San Mateo County accounts for roughly 2% of jobs in San Mateo County.

Table B-15: Midcoast and San Mateo County Employment
Employment (Jobs) Employees
Midcoast Total1 7,930
City of Half Moon Bay 5,379
Unincorporated Midcoast 2,551
San Mateo County Total2 434,295
Sources: 1City of Half Moon Bay LCLUP
2U.S. Census Bureau, County Business Patterns (CBP)

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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 73 Figure B-1: Half Moon Bay City Limits – 15-mile radius
Source: Half Moon Bay GIS
Increased demand for commercial development throughout neighboring jurisdictions has increased job growth at a high rate and has therefore contributed to the jobs-housing imbalance in San Mateo County. The City is highlighting the growth of the region as a nongovernmental constraint that will continue to place pressure on the cost of housing within Half Moon Bay. To support Half Moon Bay residents of all income levels, the City will need to focus on the development of affordable housing as presented in the Housing Resources technical report of the Housing Element. The city’s proximity to jurisdictions that have seen considerable employment growth since 2010 will continue to challenge the cost of housing in Half Moon Bay. 340
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 74 Approval Time and Requests for Lesser Densities
State Housing Element law requires the non-governmental constraints analysis to evaluate developer requests to build at densities below the density identified in the Housing Element sites inventory. Recent developments have come in within the allowed density range. Using 650 Mill Street (APN 056-164-050) as an example, a 5-unit mixed-use development (100% affordable) will be completed on a quarter-acre lot in the C-D zoning district in addition to the single existing unit (a historic resource). This district allows for densities of up to 30 units per acre (8 units on this site), with minimum densities only applicable for residential-only projects.

Mixed-use projects have no minimum density.

State Housing Element law requires the non-governmental constraints analysis to examine the length of time between receiving approval for a housing development and submittal of an application for building permits. The length of time between application approval and building permit issuance is influenced by a variety of factors, none of which are directly impacted by the City. These factors can include, but not limited to: required technical or engineering studies; completion of construction drawings and detailed site and landscape design; securing construction and permanent financing; and retention of a building contractor and subcontractors. In Half Moon Bay, most approved projects are constructed in a reasonable time period, with smaller projects generally moving more quickly than larger projects. For example, the 650 Mill Street project received planning approval in October 2020 and submitted building permits 5 months later, in March 2021. The project will was be finaled and completed in 2024.

This example is typical of past developments.
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INFRASTRUCTURE CONSTRAINTS
The Coastal Act requires that priority be given to certain land uses for allocation of public works capacities, including water supply and wastewater treatment. The LCP therefore establishes policies and regulations that require the reservation of infrastructure capacity for the following Coastal Act priority uses as defined in Chapter 18.05 Water and Sewer Capacity Allocation and Reservation, of the Zoning Code:
 Commercial Recreation
 Public Recreation
 Indoor Floriculture
 Outdoor Agriculture and Horticulture
At the same time, Government Code Section 65589.7 requires water and sewer service providers to grant priority for the provision of water and sewer services to proposed developments that include housing units affordable to lower-income households. Affordable housing is established as a local priority use in the LCLUP as described earlier in this chapter. It is also acknowledged as a priority use in Chapter 18.05 of the Zoning Code.

Coastal Act priority uses are the top tier. Affordable housing is next. All other uses, such as market rate housing, industrial uses not related to agriculture or recreation, and office uses, comprise the bottom tier, referred to as non-priority uses. Farmworker housing qualifies as both a local priority use being affordable housing, as well as a Coastal Act priority use because it is a necessary part of agriculture and horticulture uses. Thus, farmworker housing is top tier.

Water
Half Moon Bay is served by the Coastside County Water District (CCWD), which also serves portions of the unincorporated area of San Mateo County, including Princeton-by-the-Sea, the northern portion of Miramar, and El Granada. CCWD’s primary water supply, approximately 75% of the District’s supply, is purchased from the SFPUC. Local additional sources include the Pilarcitos Well Field and Denniston Creek.

Water Service Reliability: Urban water management plans (UWMPs) are updated every five years. In comparison to the 2015 UWMP, CCWD’s 2020 UWMP acknowledges significant water service reliability impacts. The primary factor is drought. The District continues to have sufficient supply in normal (non-drought) water years to meet both existing and projected demand.

However, supply and demand models anticipate shortages of up to 29% in a single dry year scenario; and up to 50% for a multiple dry year scenario.8 The UWMP includes a water shortage
contingency plan. The uncertainty of long-term water supply reliability should be considered a constraint on residential development, potentially to an increasing extent over time, unless increased conservation or new supplies can be secured.
8 County Coastside Water District 2020 Urban Water Management Plan, Executive Summary, page ES-3; https://coastsidewater.org/reports_and_studies/2020-Urban-Water-Management-Plan.pdf 342
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 76 Water Supply: CCWD and its service area have several options to reduce existing water use through conservation and to increase water supply sources. These include, but are not limited to the following:
 Best Management Practices (BMPS) for Conservation: Residential water surveys, plumbing retrofits, and system audits are typical conservation BMPs. Specific examples include high efficiency toilet rebate programs, lawn replacement programs, and residential audits. CCWD actively works on BMPS with its customers.  Local Sources: CCWD’s local sources include ground water and surface water diversions.

The District has options for expanding the use of local sources subject to further study and permitting.
 Water Recycling: CCWD’s 2020 UWMP presents strong interest in and an approach to establishing recycled water as a new water source. This would be coordinated with the wastewater agency, who would be the recycled water provider and CCWD would be the recycled water delivery agent; noting that for this to occur, significant infrastructure upgrades at the wastewater treatment plant are needed. Although recycled water is not potable, potential uses are landscape irrigation, agriculture, or groundwater recharge.

The City’s LCLUP policy supports establishing recycled water on the Midcoast.

Water Connections: Development projects are required to have a water service connection to receive water. The number of connections that CCWD can issue was established through past coastal development permitting. There are three types of connections: Coastal Act priority connections reserved for Coastal Act priority uses; affordable housing connections reserved for residential units affordable to low and lower-income households; and non-priority connections for all other uses, including market rate and moderate-income housing. In 1988, CCWD pre-sold all its non-priority water connections to fund major infrastructure improvements. Many of these connections remain available through a secondary market of numerous property owners who have purchased these connections. In general, one connection is needed per single-family home; but often more than one multi-family unit can be served by a single connection.

Thus, regardless of the availability of water, CCWD does not have an unlimited number of water service connections available. As of 2020, CCWD had 209 Coastal Act Priority water connections and 202.5 affordable housing water connections. Priority connections purchased from CCWD are about $16K each. The secondary market held about 820 nonpriority connections.9 Though nonpriority connections are not available for purchase from CCWD, property owners and developers may find an entity with available non-priority connections and arrange to purchase the allocation at market rate. CCWD maintains a list of entities and details on the uninstalled water connections within its service area. City staff is aware, anecdotally because these prices are not regulated, that the going price for a market rate connection in 2023 was approximately $80K - $100K. There is no question that the cost of non-priority connections constrains residential development; 9 City of Half Moon Bay, Local Coastal Land Use Plan, Chapter 3: Public Works, pages 3-13 – 3-14; https://www.half-moon-bay.ca.us/DocumentCenter/View/3758/Chapter-3-Public-Works 343
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 77 especially multi-family development that does not qualify for affordable housing priority connections.

Overall, the number of priority connections is beginning to run low relative to RHNA for Half Moon Bay and the portion of unincorporated coastal San Mateo County within the CCWD service; this will become a severe constraint on affordable housing at the low and lower-income levels unless more connections can be established. Establishing more connections will require amendments to previously issued coastal development permit(s). This is a complex matter outside the City’s direct control requiring Coastal Act and LCP conformance whereby the District and its customers must demonstrate that the connections are needed, and that the establishment of such connections will not be growth inducing beyond the capacities of other types of infrastructure, including wastewater treatment and circulation.

Wastewater
Sanitary sewer service is provided by the City of Half Moon Bay and Granada Community Services District (GCSD) for transporting sewage flows and Sewer Authority Mid-Coastside (SAM) for treating and disposing of the sewage. SAM is a public agency providing wastewater treatment services to Montara Water and Sanitary District, GCSD, and Half Moon Bay under a joint powers agreement. Each member agency of SAM is allotted maximum capacity rights for peak wet weather floor (PWWF), average dry weather flow (ADWF), biochemical oxygen demand, and suspended solids. These allocations correspond to the sewer treatment capacity and the sewer transmission capacity.

Sanitary Sewer Infrastructure: The City of Half Moon Bay’s existing sanitary sewer system consists of approximately 37 miles of sewer mains, approximately 3,100 laterals, and three lift stations. GCSD’s sanitary sewer system includes approximately 33 miles of sewer line and approximately 1,500 feet of force main running along HWY 1. SAM owns and operates an 8-mile stretch of transmission main. Four main lift stations are used to connect the three member agencies’ sewer distribution systems to the SAM Treatment Plant.

Treatment Plant Capacity: The City’s LCLUP identified that treatment capacity could become overtaxed at or before buildout modeled for the LCLUP’s 2040 planning horizon. The City’s approach to addressing this in the near-term has been to reduce the high level of inflow and infiltration (I&I) whereby excess water from stormwater and groundwater flows into older, faulty sewer pipes. Reduction of I&I is costly, yet effective. Another approach to increasing treatment capacity is to establish a water recycling facility. Despite other potential tangible options to increase treatment plant capacity (and establish a new water source if water recycling is implemented), the ultimate challenge is that the treatment plant is very low-lying and immediately adjacent to the coast; it is already subject to flood events from intense storms and will become more vulnerable to sea level inundation over time. Protecting the plant from this risk is being studied by SAM.

Traffic and Roads
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 78 Half Moon Bay is connected to the region by State HWYs 1 and 92. The City’s policy, as established in the 2013 Circulation Element, is to maintain level of service (LOS) C as the desired LOS on both highways except during the peak two-hour commuting period and the 10-day average peak recreational hour, during which times LOS E is acceptable. For the purposes of CEQA, LOS is no longer a threshold of significance, having been replaced by vehicle miles traveled (VMT). The recently certified LCLUP harmonizes the two standards by retaining LOS from a policy perspective for maintaining coastal access, but utilizing VMT as the threshold of significance for CEQA analysis purposes.

LOS: LOS is a quality measure that describes operating conditions within a traffic stream. LOS evaluation indicates the degree of congestion that occurs during peak travel periods and is the principal measure of roadway and intersection performance. It is described in terms of speed and travel time, freedom to maneuver, traffic interruptions, and comfort and convenience. LOS can range from A (representing free-flow conditions) to F (representing extremely lengthy delays).

LOS D is typically considered acceptable for a peak hour in urban areas. LOS E is approaching capacity and LOS F represents conditions at or above capacity.

LOS evaluations for roadway segments and intersections along the highways were conducted as part of the 2013 update to its General Plan Circulation Element and the 2020 LCLUP. The LCLCUP assessment confirmed the 2013 Circulation Element evaluation that the weekend traffic peak is severe on the Coastside and in Half Moon Bay. The weekday AM and PM peak hours are also experiencing heavy congestion, with an elevated level of out-commuting as well as overlapping school trips that are not adequately supported by public transit or any school buses.

VMT: VMT measures the total number of miles traveled that originate or terminate within a defined area over a specified period. VMT has a stronger connection to environmental impacts including greenhouse gas emissions, energy use, and runoff pollution. As of the update of the Cycle 6 Housing Element, the City was preparing its VMT threshold for CEQA assessment. The draft threshold followed the California Office of Planning and Research guidance for a 15% reduction and was in review.

As individual development projects are proposed in Half Moon Bay, they will be reviewed for their potential to result in project-level LOS impacts and their contribution to the City’s VMT.

Individual development projects will continue to be conditioned to provide traffic improvements to reduce significant impacts on specific roadway operations from a policy perspective; and will also now require transportation demand management or other approaches to address VMT. As noted at the beginning of this technical report, VMT is especially difficult to address in Half Moon Bay because the city has limited transit service and is subject to significant visitor traffic; resulting in the city’s transportation impact zones (TAZs) having relatively high VMT compared to other San Mateo County jurisdiction. Adhering to State VMT requirements may become a development constraint for residential development; however, the City will seek all exemptions for affordable housing.
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HISTORICAL AND ENVIRONMENTAL CONSTRAINTS
Residential development in Half Moon Bay is constrained by the presence of resources and hazards, which are addressed by policies in the LCP. Historic and environmental conditions, including resources and hazards, constrain development both in terms of location and affordability.

Archeology
The City has mapped areas with high potential for archaeological resources; many vacant lands, especially those near watercourses, are in sensitive locations. Archaeological reports are required for projects located within any designated archaeological resource area or 100 feet from any recorded archaeological site identified in the LCLUP. Necessary studies and mitigation measures may add to the cost of a project and add to the project’s time requirements.

ESHA
Beyond the multi-layered and complex regulatory framework, the presence of ESHA restricts development due to the condition of the land. Many ESHA areas are associated with water resources including watercourses and wetlands. Such areas are located throughout the city and are not appropriate for development.

Geological
The greater Half Moon Bay landscape consists of a gently sloping marine terrace. The western edges consist of coastal bluffs and sandy shoreline. The northeastern section contains steep hills with erosion potential. The city is underlain with poorly consolidated shallow marine sands, silts, and gravels resting on top of an ancient wavecut bedrock platform. Most soils are derived from alluvial sources, as the geology of the city is defined to a substantial extent by the sea, the San Gregorio Fault, and wetlands and watercourses. This context sets the stage for a range of geological hazards including erosion, landslides, subsidence, and seismic risks (e.g., rupture, liquefaction, and slope failure). Geologic hazards are moderate to low within the city, though some areas of high landslide risk exist along the eastern edge of the city. Geological reports for areas in geologically hazardous areas are required. Geological hazards present a contain in some cases as geotechnical engineering, grading, and lot preparation costs to reduce these potential hazards can increase the cost and time requirements of development.

Flood
Many properties in Half Moon Bay are subject to one or more hydrologic hazards. These include localized flooding near creeks and other watercourses; inundation from tsunami and/or dam failure; and coastal flooding. All these hazards are heightened by climate change and sea-level rise. Constraints associated with these hazards will influence future development efforts and may require measures to minimize impacts. Some hazard types, such as flood and tsunami inundation zones, have been previously delineated and policies have been adopted that discourage or 346
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 80 regulate development proximate to these areas. Delineation of areas susceptible to sea-level rise has been prepared and continues to be updated as best available science evolves.

The LCLUP limits new development on bluff faces, on bluff and cliff tops, and in areas prone to serious flooding due to tsunami or dam failure. Most of the sites in the Housing Element site inventory are located away from such hazards; others require analysis and possible mitigation such as raised foundations or evacuation plans. Absent such care, otherwise well located and viable sites cannot be considered for residential development.

Fire
Wildland fires in the west have become prevalent and much more difficult to contain with prolonged drought periods and increasing temperatures. Fire hazard is typically more prevalent in inland areas which do not benefit from moist marine climatic conditions; however, with climate change, even coastal settings undergo extremely dry periods during extended droughts.

Much of the eastern edge of the city limits, as well as some areas within the city, are mapped in the high or very high fire severity area. One of the larger sites in the Cycle 5 Housing Element was located within the very high fire severity zone; and has consequently been removed from the inventory. Some of the Cycle 6 Housing Inventory sites are located adjacent to these areas, but none are within them. Care with setbacks and fuel load will need to be considered when planning for housing on these sites.
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LOCAL EFFORTS TO REMOVE CONSTRAINTS
Key local efforts to remove constraints associated with each conflict topic – Governmental, NonGovernmental, Infrastructure, and Historic and Environmental – are provided below in the conclusion of this technical report.

Governmental
The City’s primary focus, which has produced a portfolio of successes, is the certification of the LCLUP. This comprehensive update harmonizes the requirements of the California Coastal Act with State housing law and the city’s housing needs. It is a remarkable achievement, demonstrated by the following highlights:

Long-Term Housing Needs: The 2020 LCLUP comprehensive update set out to overcome significant constraints on residential development and to proactively enable well-located and viable sites for affordable housing in anticipation of the Cycle 6 and subsequent RHNA cycles.

Furthermore, City staff worked with numerous property owners and developers throughout the multi-year LCLUP update process to ensure that housing sites enabled by LCLUP would not only have development potential, but would also likely be developed in the early years of enactment of the LCLUP, which overlaps with Cycle 6.

The Best Sites - Town Center and Workforce Housing Overlay (WHO): The LCLUP, and the forthcoming implementation zoning, set up housing sites in locations that will provide supportive, convenient, and quality living environments. The Town Center sites are concentrated near all the city’s public schools, grocery stores, transportation corridors, and numerous other services. Many of the WHO sites will provide housing near employment, while the rest of the WHO sites are in or near the Town Center. The LCLUP laid these sites out with deliberate intent for furthering the best options when it comes to new housing.

Affordable Water Connections for Affordable Housing: The City led an effort to resolve a problem imposed by an unresolved constraint stemming from one of CCWD’s coastal development permits. These permits established and limited CCWD’s water connections by number and type for specified land uses that a connection could serve. As described in the Infrastructure section of this report, three types of connections were established: Coastal Act priority, local priority for affordable housing, and non-priority. The non-priority connections are only available through a secondary market of landowners and cost about $80K - 100K, whereas the priority connections are held by CCWD and cost about $16K.

Due to CCWD’s interpretation of conditions of approval for a coastal development permit issued to the District, the District would not issue water connections for affordable housing in Half Moon Bay. Yet, at the same time, the District continued to make these connections available to the unincorporated Midcoast within the CCWD service area for the same type of affordable housing units. This matter plagued the City for most of the Cycle 5 Housing Element despite efforts by City staff for several years to sort out the matter. Working with the California Coastal Commission and CCWD, and through the LCLUP update process, the City successfully facilitated a resolution. 348
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 82 CCWD and the Coastal Commission agree: these crucial water connections, established solely for housing units affordable to households at the low or lower-income level, are available to qualifying development in the entire CCWD service area including the unincorporated Midcoast and the City of Half Moon Bay. This situation has been one of the most significant constraints on affordable housing development in Half Moon Bay for many years, and it is finally resolved.

Non-Governmental
The primary non-governmental constraint is the overall cost of affordable housing development, which includes high land and development costs. Constructing affordable housing often requires subsidies beyond available density and/or financial incentives that support affordable housing developers’ efforts to leverage multiple funding sources.

While the City can offer developer incentives such as expedited permit processing, density bonuses, and fee deferrals, it cannot afford to fully mitigate the high cost of affordable housing development. The City's affordable housing fund relies on proceeds from construction and development fees, including in-lieu fees that are restricted to affordable housing development.

Per Program 4-6, the City will determine if an affordable housing linkage fee on commercial developments would be a viable way to increase available affordable housing funds. Such a source would be limited because non-residential development on the Coastside is quite limited, especially in comparison to Bayside cities.

The City can also offer City-owned lands for affordable housing development, per Program 4-8.

Although the City has limited land holdings with development potential, it is making strides along these lines. In February 2022, the City released a request for qualifications for an affordable housing development of City-owned property at 555 Kelly Avenue; the process is proceeding with 40 units of farmworker housing to be developed by a non-profit housing developer. In addition to 555 Kelly Avenue, the City-owned 880 Stone Pine Road site is included in the Cycle 6 sites inventory presented in Housing Resources Appendix C. Notably, both 555 Kelly Avenue and 880 Stone Pine Road are recent acquisitions. Absent these properties, the City’s land holdings include City parks and facilities sites, and other lands with significant development limitations due to the presence of ESHA, including wetlands.

Infrastructure
Water: With careful conservation and adherence to CCWD’s water shortage contingency plan, there should be sufficient water supply, as well as water connections, for development of housing units to meet the City’s RHNA. However, beyond the Cycle 6 RHNA, and in consideration of development that may be proceeding in the unincorporated County portion of CCWD’s service area, limited water supply and water connections for affordable housing will need to be seriously considered. This may require investment in new supplies and coastal development permitting to establish additional water connections. The City’s LCLUP policies support both efforts, however, the City would not be the lead agency for either of these endeavors and will need to continue to track this issue and collaborate with CCWD, SAM, and the California Coastal Commission. 349
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 83 Wastewater: Wastewater treatment capacity should be adequate for the Cycle 6 RHNA and other projected development, possibly to about 2040, the LCLUP’s planning horizon. The wastewater conveyance infrastructure in the City of Half Moon Bay and throughout the rest of the SAM service is being improved through ongoing capital improvement program projects. In particular, the City has focused on reducing I&I, which results in direct and immediate reductions in wet weather wastewater flows. This is advantageous for supporting Cycle 6 RHNA because wet weather flows are the primary near-term treatment capacity challenge. The City’s five-year capital improvement program includes ongoing I&I reduction projects, demonstrating commitment to this effort. Beyond reducing I&I, supporting recycled water, and protecting the SAM plant and infrastructure from sea level rise impacts are supported by LCLUP policies.

However, as in the case of water supply, the City would not be the lead agency for such projects, which are large-scale and require significant investment. The City is keenly aware of these system weaknesses and will continue to collaborate with other agencies to address these needs well in advance of reaching capacity limits.

Traffic and Roads: The city’s roadways experience three acute peak use periods: weekday mornings, weekday evenings, and weekends which may have numerous peaks that can be quite extensive. There is limited room to increase roadway capacity. Instead, City policy supports improving safety and expanding transportation modes through Town Boulevard planning, which focuses on HWYs 1 and 92. The associated land use strategy, reflected in the Cycle 6 sites inventory is to locate housing in the Town Center and near employment.

Historic and Environmental
The City seized the opportunity in comprehensively updating the LCLUP to align land use designations such that future development, to the extent feasible, would avoid resources (e.g., archaeologic resources and ESHA) and hazards (e.g., geologic, hydrologic, and fire). The City intended to address conflicts in anticipation of future LCLUP implementation. As such, to a significant extent, the LCLUP is self-mitigating. Although some Cycle 6 Housing Element sites will require special consideration for resources and hazards, the City’s forethought in this work has shone a light on what otherwise may have been unexpected conditions such as the case of unknown wetlands or flood risk that could be costly to manage in the best case, or render sites unviable in the worst case.

Summary
There are significant constraints affecting housing development in Half Moon Bay, but recent, current, and planned policies and programs are helping to address them. Half Moon Bay’s Cycle 6 Housing Element update overcomes both real and perceived capacity limits, addresses many of the community’s unmet needs, and moves on from long-held beliefs that the Coastal Zone is not amenable to affordable housing development. Program 2-4 (Mobile Home Park Affordability Protections, Program 3-4 (Housing for Essential Workers), and Program 3-6 (Childcare) are just a few examples of the range of approaches included in the Cycle 6 Housing Element that will lead to improved living conditions and access to resources for the city’s most vulnerable populations. 350
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix B - Constraints Page | B - 84 Furthermore, the primary capacity constraints identified at the beginning of this report have been evaluated and addressed to the extent feasible as recapped here:
 Land: The Housing Opportunity Sites (presented in Technical Report Appendix C – Housing Resources), take advantage of the LCLUP’s approach to infill development of sites within Town Center, public and quasi-public-owned lands, and on properties devoted to agricultural and horticultural uses.
 Infrastructure: Well-located infill housing at appropriate densities requires less water and generates lower VMT than single-family subdivisions, which make up most of the City’s housing stock. The City needs to be careful about the “infrastructure footprint” of new development and is doing so with both the LCLUP and the Cycle 6 Housing Element.  Funding: Program 4-6 (Increased Funding for Affordable Housing) and Program 4-7 (Affordable Housing Fund Management and Use) will help establish new sources for the affordable housing fund, and leverage other sources. The City has also invested in staffing resources.

In concluding this report, it is worth reiterating that the Coastal Commission and the City of Half Moon Bay have come to a meeting of the minds when it comes to housing. The comprehensive LCLUP update, through land use designations and policies, set the table for the Cycle 6 Housing Element for workforce housing, farmworker housing, affordable housing, missing middle housing, manufactured housing, multi-family housing, and housing in mixed-use development.

The City is grateful to the California Coastal Commission for certifying Half Moon Bay’s LCLUP, as submitted, inclusive of its forward-thinking housing-friendly policies. 351
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 1 Technical Report Appendix C: Housing Resources
The Half Moon Bay Local Coastal Land Use Plan (LCLUP) / General Plan land use designations and policy provide ample sites and support for residential development to meet the city’s share of the region’s future housing needs. Although located within a large metropolitan area, Half Moon Bay is a small town with rural qualities, including active coastal agriculture land uses and a lack of high-quality transit. As such, the City’s housing needs cannot be accommodated with traditional urban approaches employed by San Mateo County’s bayside cities, where highdensity development can often be concentrated near transit centers and other resource areas.

Instead, the City’s approach must be much more nuanced. The City, being wholly within the Coastal Zone, is obligated by the California Coastal Act and its certified Local Coastal Program (LCP) to prioritize certain land uses, including agriculture, public recreation, and a range of services to support coastal visitors. These industries offer lower wage jobs, which being set in the landscape of the very high-cost greater Bay Area, makes it extremely challenging for employees of these industries to afford housing on the Coastside. The City’s housing resources are sensitive to these conditions as presented in the technical report.

REGIONAL HOUSING NEEDS ALLOCATION - RHNA
For the Cycle 6 Housing Element, the City of Half Moon Bay was allocated 480 units. These units are divided by income category, based on the 2022 San Mateo County Area Median Income (AMI) of $166,000.1 The 480 units include 285 lower-income units (181 at very low income, or less than 50 percent of AMI, and 104 at low income, or 50-80 percent of AMI), 54 moderate-income units (80-120 percent of AMI), and 141 above-moderate-income units (more than 120 percent of AMI) as part of its Regional Housing Needs Allocation (RHNA).

Table C-1: Half Moon Bay Cycle 6 RHNA
Income Category
Lower
Moderate Above
Moderate Total
Very Low Low
Proportion of
Area Median
Income
0%-50%
AMI
50%-80%
AMI
80%-120%
AMI
> 120%
AMI
Allocation 181 104 54 141 480
Source: Association of Bay Area Governments, “Adopted Final RHNA Plan” (December 2021) 1 2022 San Mateo County Income Limits (HUD: April 18, 2022): https://www.smcgov.org/media/126576/download?inline 352
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 2 The City will fulfill this RHNA from three sources: Pipeline Projects, Housing Opportunity Sites, and accessory dwelling units (ADUs). Pipeline Projects and Housing Opportunity Sites are mapped in Figure C-1.

Figure C-1: Pipeline Projects and Housing Opportunity Sites Source: City of Half Moon Bay
353
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 3 The California Department of Housing and Community Development (HCD) recommends that jurisdictions create a buffer in the housing element inventory of at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower-income RHNA, to ensure that sufficient capacity exists in the housing element to accommodate the RHNA throughout the planning period.2 Half Moon Bay’s Cycle 6 Housing Element has buffers of 34% for lower-income units, 257% for moderate-income units, and 72% for above moderate-income units.

Table C-2: Meeting RHNA

RHNA
Income Category
Very Low Low Moderate Above
Moderate Total
181 104 54 141 480
Total Units 250 159 134 239 782
Pipeline 62 25 70 185 342
ADUs 34 34 34 10 112
Housing
Opportunity
Sites
154 100 30 44 328
Surplus Units 70 55 79 98 302
Buffer 38% 53% 148% 70%
Source: City of Half Moon Bay
HOUSING SITES INVENTORY - MEETING CYCLE 6 RHNA
Half Moon Bay will meet its housing needs and exceed RHNA obligations with sites from 37 Pipeline Projects, 12 Housing Opportunity Sites, and 112 ADUs. A parcel-by-parcel inventory of the Pipeline Projects and Housing Opportunity Sites is available at the end of this technical report. 2 HCD Division of Housing Policy Development “Housing Element Site Inventory Guidebook Government Code Section 65583.2” (HCD: June 10, 2020), p.22. Available at https://www.hcd.ca.gov/communitydevelopment/housing-element/docs/sites_inventory_memo_final06102020.pdf 354
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 4 Pipeline Projects
Half Moon Bay currently has 37 pipeline projects, meaning projects in the city’s development “pipeline” between formal proposal and receiving a certificate of occupancy. These 37 projects (comprising 48 parcels) contain 342 units: 87 allocated for lower-income units (62 very low and 25 low), 70 allocated for moderate-income units, and 185 allocated for above moderate-income units.

As it relates to the project pipeline, the Technical Report on Constraints provided in Appendix B presents additional details about the California Coastal Act in the Governmental Constraints discussion. The Coastal Act regulates land use within the California Coastal Zone. Half Moon Bay is wholly within the California Coastal Zone and therefore the Coastal Act heavily affects the City’s land use planning context and regulations for new development. To approve development within the Coastal Zone’s boundary, a local jurisdiction must prepare an LCP subject to California Coastal Commission certification. Once the LCP is certified the local jurisdiction can then process coastal development permits. Most housing development in the Coastal Zone requires that a coastal development permit be approved to advance. Another constraint identified is the City’s residential growth control measure. In Half Moon Bay, residential growth is limited to, in any particular year, the number of dwelling units that would result in an increase of up to 1.5% of the city’s population as of January 1 of that year. This residential growth limitation was incorporated into the LCP by amendment after the passage of the voter initiative “Measure D” in 1999 and subsequent certification by the Coastal Commission in 2009, as well as recertification with the 2020 LCLUP update in 2021. Because it is a ballot measure approved by the voters, Measure D can only be amended by a vote of the people (and subsequent certification by the Coastal Commission) or through State legislation. A more detailed discussion of Measure D can be found later in the Government Constraints chapter, in the section titled Residential Growth Limitation Ordinance.

Table C-3: Pipeline Projects Overview

Income Category
Lower Moderate Above Moderate Total
RHNA 285 54 141 480
Pipeline 87 70 185 342
Source: City of Half Moon Bay
The majority of these projects are small-scale developments of fewer than 10 units. There are five larger developments ranging from 15 to 167 units: Projects A, D, AH, AI, and AJ. Increasing costs (e.g., interest rates) and development uncertainty since 2020 have acted as a general impediment in Half Moon Bay. Compared to the bay side of San Mateo County, there is less demand pressure on coastside communities in San Mateo County, which has led to a pause – 355
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 5 particularly on larger projects. These non-governmental constraints are discussed in Chapter B.

There are no other known barriers or constraints to development in the planning period.

The complete table of pipeline projects, their addresses, their unit allocations, and their current pipeline status is below:

Table C-4: Pipeline Projects
Site
Income Category
Pipeline Status* Total Very
Low Low Mod
Above
Mod
A
Seymour Street @
HWY 1
(APN 064-352-150)
20 4 4 12 0
Final EIR issued
including for an
associated hotel in
review; 4 duplexes
totaling 8 units, plus
ADUs
Anticipated
completion: 2026
B
565 & 575 Seymour
Street
(APNs 064-342-370, 380)
2 0 0 0 2
565: Active planning
application;
Anticipated
completion: 2026
575: BP Pending
Anticipated
completion: 2025
C 650 Mill Street
(APN 056-164-050)
5 0 1 4 0
Under construction,
Mixed-use with 5 units
over commercial
Anticipated
Completion: 2024
D 320 Church Street
(APNs 056-150-010, -020)
15 2 2 0 11
CDP pendingissued
and building permits
under review; deed
restriction recorded
for 2 very low- and 2
low-income units
Anticipated
completion: 2026
E 403 Chesterfield St.
(APN 056-055-110)
1 0 0 0 1 Measure D under
reviewnot submitted
356
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 6 Site
Income Category
Pipeline Status* Total Very
Low Low Mod
Above
Mod
Anticipated
completion: 2026
F 574 Magnolia Street
(APN 064-342-230)
1 0 0 0 1 CDP expired
G 433 Main Street
(APN 056-166-110)
6 0 2 2 2
BP Pending, Mixed-use
with 6 units over
commercial
Anticipated
completion: 2025
H
700 Monte Vista Ln.
(APNs 056-210-370, 380)
6 0 2 2 2
Measure D issued
Incomplete
Application; Director
Review
Anticipated
completion: 2026
I
700 Block Monte
Vista Lane
(APN 056-210-390)
2 0 0 1 1
Measure D issued
Anticipated
completion: 2026
J 2778 Pullman Ave.
(APN 048-133-040)
1 0 0 0 1 Completed in 2024
K 698 Terrace Avenue
(APN 056-081-390)
1 0 0 0 1 Completed in 2024
L 549 Grove Street
(APN 064-261-300)
1 0 0 0 1
Under construction
Anticipated
completion: 2024
M 341 Myrtle Street
(APN 064-061-280)
1 0 0 0 1
Under construction
Anticipated
completion: 2024
N 909 Grandview Bl.
(APN 048-264-250)
1 0 0 0 1 Completed in 2024
O 336 Myrtle Street
(APN 064-062-570)
1 0 0 0 1 Completed in 2024
P 300 Main Street
(APN 056-163-080)
10 0 9 1 0 Conversion of existing
bed and breakfast
357
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 7 Site
Income Category
Pipeline Status* Total Very
Low Low Mod
Above
Mod
units into apartments,
under construction,
anticipated
completion in 2025
Q 493 Kelly Avenue
(APN 056-141-430)
1 0 0 0 1
Under construction
Anticipated
completion: 2025
R 655 Potter Avenue
(APN 056-108-170)
1 0 0 0 1
BP issued
Anticipated
completion: 2025
S 795 Main Street
(APN 056-192-160)
2 0 0 2 0
BP Issued
Anticipated
completion: 2024
T 727 Main Street
(APN 056-192-210)
1 0 0 0 1 Completed in 2023
U 0 Miramontes Ave.
(APN 056-102-070)
1 0 0 0 1
BP issued
Anticipated
completion: 2025
V 540 Purissima Street
(APN 056-171-130)
1 0 0 0 1
CDP pending, project
modified to include
increase number of
units
Anticipated
completion: 2026
W 2411 Cabrillo Hwy. S
(APN 066-082-050)
7 4 3 0 0
CDP under
reviewissued for first 3
units
Anticipated
completion: 2026
X 8 Jenna Lane
(APN 056-072-390)
1 0 0 0 1
BP issued
Anticipated
completion: 2026
Y 390 Redondo B. Rd.
(APN 066-092-870)
1 0 0 0 1 BP issued
358
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 8 Site
Income Category
Pipeline Status* Total Very
Low Low Mod
Above
Mod
Anticipated
completion: 2024
Z 563 Myrtle Road
(APN 064-103-220)
1 0 0 0 1
BP issued
Anticipated
completion: 2024
AA 435 Johnston Street
(APN 056-168-080)
1 0 0 0 1 Completed in 2024
AB 316 Grove Street
(APN 064-222-250)
1 0 0 0 1
CDP under reviewand
Building Permit issued
and under
construction
Anticipated
completion: 2026
AC 63 Guerrero Avenue
(APN 048-085-250)
1 0 0 0 1
BP issued
Anticipated
completion: 2026
AD 419 Garcia Avenue
(APN 056-118-190)
1 0 0 0 1
BP under review
Anticipated
completion: 2026
AE 716 Monte Vista Ln.
(APN 056-210-180)
1 0 0 0 1
Measure D Issued
(*July 29, 2021); Flag
lot subdivision. CDP
application submitted
Anticipated
completion: 2027
AF Poplar Street & 4th
(APN 064-271-290)
1 0 0 0 1
BP under review
Anticipated
completion: 2027
AG 219 Pilarcitos Road
(APN 056-141-330)
3 0 0 3 0
BP issued
Anticipated
completion: 2027
AH
250 San Mateo Road
(APNs 056-310-190, 056-
230-170)
32 0 0 32 0
CDP under review
Anticipated
completion: 2027
359
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 9 Site
Income Category
Pipeline Status* Total Very
Low Low Mod
Above
Mod
AI
75 Main Street
(APNs 056-310-120, 056-
310-080)
167 12 11 11 133
Prelim application
complete with 250
units; 40 affordable
units. Project revised
to mixed use with 81
affordable units, 34
market rate units, and
75 square feet of
office
space. Remaining
steps include CDP and
Specific Plan, which
would require an LCP
amendment.

Anticipated
completion unknown,
waiting for formal
submittalProjected
completion: 2028
AJ 555 Kelly Avenue
(APNs 056-150-200, -220)
40 40 0 0 0
City-owned site; CDP
issued in 2024, 100%
affordable to very lowincome farmworker
households.

Anticipated
completion in 2027
AK
201-208 Carnoustie
Court
(APNs 066-670-010, -020,
-030, -040, -050, -060, -
070, -080)
8 0 0 0 8 Completed in 2023
TOTAL 342 52 35 70 185
Source: City of Half Moon Bay
*KEY: BP = Building Permit; CDP = Coastal Development Permit; Measure D = Growth Limit Allocation *Sites A, D, H, W, AI, and AJ already have, or will have, recorded affordability agreements. **Sites C and G include small fully accessible units that the City understands will be affordable to low-income households based on from communication with owners/developers. The City cannot require affordable agreements for these units despite effort made to offer concessions. 360
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 10 Notably, constraints already have, or may affect, some of these larger projects. • Site A (Seymour Street @ Highway 1): Development of this site is being considered in an environmental impact report (EIR) as part of a larger development for a new hotel project.

Thus, it is constrained from the perspective of a regulatory process that would otherwise likely qualify for an exemption under the California Environmental Quality Act (CEQA). • Site D (320 Church Street): This site was previously subject to significant permitting hurdles, including an appeal to the Coastal Commission. Fortunately, the subdivision is fully entitled and the remaining permitting is underway and moving along.
• Site AH (250 San Mateo Road): This 32-unit expansion of Hilltop Mobile Home Park is progressing through the entitlement process. The City is working with the applicant to determine if a CEQA exemption can be supported with evidence. Sometimes CEQA exemptions require a limited level of environmental review to establish evidence to ensure that the project is eligible for the exemption.
• Site AI (75 Main Street): The Podesta Planned Development site at about 34 acres is the largest of the City’s housing sites. The site has been in agricultural use and contains an agricultural irrigation pond which will have to be treated as a wetland with an associated 100-foot buffer per Coastal Act requirements. Portions of the site also have relatively steep slopes. Fortunately, with ample site area, these constraints can be worked into the site plan. There is a preliminary plan in place for the site, the City is in ongoing conversations with a developer. • Site AJ (555 Kelly Avenue): Permitting is moving forward for this City-owned property. The applicant submitted a formal planning application in Fall 2023; project financing is dependent on various State and County funding sources being approved within the next two years. Project financing is underway with ARPA and IIG funding, and additional SERNA, County NOFA, and tax credit financing to be determined. This project is expected to finalize funding sources in 2025 and commence construction in 2026. Mercy expects project completion in late 2027 or 2028. The primary constraint will be the on-going need for operational subsidies to support the extremely low-income population that will benefit from these urgently needed units. 361
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 11 Figure C-2: Pipeline Projects
Source: City of Half Moon Bay
None of the Pipeline Projects are developing on sites that currently include residential units subject to an affordability agreement. No phasing or dropouts are anticipated. In Half Moon Bay, 362
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 12 several project applicants drop out after Measure D issuances but it is very rare for any drop outs after CDP submittal. Only Site F, 574 Magnolia Street (1 above moderate income unit) had a CDP expire.

Housing Opportunity Sites
The Site Inventory includes 12 Housing Opportunity Sites comprised of 60 parcels. These sites have capacity for 328 units: 255 allocated for lower-income units (155 very low and 100 low), 29 allocated for moderate-income units, and 44 allocated for above moderate-income units. Most of the Housing Opportunity Sites are located within or near the Town Center with proximity to resources, thus fostering a more inclusive community with access to opportunities for residents. 363
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 13 Figure C-3: Housing Opportunity Sites by Affordability
Source: City of Half Moon Bay
364
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 14 Table C-5: Housing Opportunity Sites
Site
# Address/Site
LCLUP/
General
Plan
Existing
Zoning
Realistic
Unit
Capacity
Affordability
Allocation Site
Type*
1 880 Stone Pine Road
(APN 056-260-180)
PF U-R 50 Very Low
TC and
pending
WHO
2 498 Kelly Avenue
(APN 056-181-010)
PF P-S 60 Low WHO
3 300 Block Church Street
(APN 056-150-020)
PF P-S 52 Very Low TC and
WHO
4 0 Block Stone Pine Road
(APN 056-250-070)
C-G C-G 9 Moderate TC
5 101 Canada Cove Avenue
(APN 066-081-190)
MHP MHP 40 Low MHP
6 740 Purissima Street
(APN 056-182-090)
R-H R-2 12 Moderate TC
7 895 Main Street
(APN 056-210-130)
C-G C-D 4 Moderate TC
8 500 Block Poplar Street
(APNs 064-244-030, -040)
R-H R-2 5 Moderate TC
9 604 Poplar Street
(APNs 064-272-010, -020, and -
030)
R-H R-2 5 Moderate TC
10 600 Block Poplar Street
(APNs 064-272-170, -180, -190,
-200)
R-H R-2 6 Moderate TC
11 940 Main Street
(APN 064-272-100)
R-H R-2 41 Very Low TC
12 Pacific Ridge Phases 2 & 3
(APNs 056-580-010 to -180,
056-570-010 to -260)
PD PUD 44 Above
Moderate Other
Source: City of Half Moon Bay
*KEY: TC = Town Center; WHO = Workforce Housing Overlay; MHP = Mobile Home Park; Other = Known Developer Interest

365
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 15 Site Identification
The City has been working on site identification for the Cycle 6 Housing Element for several years.

The LCLUP was recently comprehensively updated and adopted by City Council in 2020 and certified by the California Coastal Commission in April 2021. Because the City is located wholly within the Coastal Zone, the LCLUP serves as the City’s General Plan Land Use Element. Therefore, in updating the LCLUP, which has a 2040 planning horizon, the City assumed that the LCLUP would need to provide adequate sites for at least two RHNA cycles. The City also assumed that RHNA would probably increase, but only to an extent that would fit within the City’s residential growth limits certified by the Coastal Commission. Overall, for the 2040 planning horizon, residential development was planned for market rate development of neighborhood infill sites, expansion of mobile home parks, affordable housing development of Workforce Housing Overlay (WHO) sites, and multi-family and mixed-use development in the Town Center. These last three categories comprise most of the Cycle 6 Housing Element Opportunity Sites. Broadly, the intent is to couple the types, locations, and affordability levels of new housing with the Coastside’s special housing needs; all while managing the footprint of development to comply with the California Coastal Act.

The justification for selection of the Housing Opportunity Sites is straightforward:

Manufactured/Mobile Homes (MHP): Mobile homes comprise over 10% of the City’s housing stock. They are much more affordable than other types of detached housing and whole neighborhoods can be developed relatively quickly. Expansion of one mobile home park is proceeding and thus is included with Pipeline Projects. Expansion of another mobile home park is included as an Opportunity Site.

Workforce Housing Overlay (WHO): By definition, development in the WHO land use designation must be affordable. These sites are in agricultural areas, and in and around the Town Center. This overlay designation was created specifically to address affordable housing needs for farmworkers, service workers, and other workforce housing needs. All the WHO Opportunity Sites have a base density of at least 20 units/acre.

Town Center (TC): Multi-family and mixed-use development throughout the Town Center that is not part of the WHO should be expected to have mixed affordability levels. These sites provide excellent access to employment and/or services. These housing types address the need for missing middle housing and the Town Center location provides access to schools, stores, and nearly all the services that Half Moon Bay has to offer. All the Town Center sites have a base density of at least 20 units/acre. Three sites, Sites #1, #3, and #4 are in the Town Center and are also covered by the Workforce Housing Overlay.

Other: Only one site not fitting in the above categories, Site #12, is included in the Cycle 6 Housing Element Opportunity Sites. This site is located close to the Town Center, infrastructure is in place, and there is developer interest.
366
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 16 Site Capacity and Adjustment Factors
State guidelines require jurisdictions to calculate the projected residential development capacity of sites using one of two options: minimum densities or adjustment factors. Half Moon Bay’s 6th Cycle Element utilizes adjustment factors to identify a site capacity for each of the sites. HCD recommends using five adjustment factors to determine the realistic site capacities for parcels in a jurisdiction’s site inventory:

Land Use Controls: Cumulative impact of development standards on residential development capacity must be taken into account. Land Use Controls were identified based on the Site Type (MHP, WHO, TC, TC/WHO, Other).

Based on analysis of the current zoning code and development standards, the WHO relieves any cumulative impact on the maximum development potential for opportunity sites, and there is little to no cumulative impact on the maximum development potential of opportunity sites in the Town Center area. However, minimum setbacks, open space, parking, and access requirements impact development in the Mobile Home Park (MHP) zoning district. Therefore, a conservative capacity factor of 95% was given for WHO to account for sidewalks and easements; the Town Center area was given a 90% capacity factor to account for some of the small and/or challenging site geometries on infill sites; and the MHP area was given a 66% capacity factor to account for the impacts of land use controls in the zoning district.

Realistic Capacity: Realistic potential for residential development capacity is based on potential for development with nonresidential uses or requirements of redevelopment. Realistic Capacity was identified based on the Site Type (MHP, WHO, TC, TC/WHO, Other).

The WHO site is given a 97% realistic capacity factor based on the extremely high likelihood of residential development on a school site provided by the overlay itself. The Town Center area was given an 85% realistic capacity factor to acknowledge the slight – but present – possibility that non-residential development may occur on infill sites in the Town Center (including on TC/WHO properties). The MHP area is assigned a 75% realistic capacity factor to account for the lower likelihood of redevelopment based on the lower land values of mobile home parks.

These factors are based on development trends seen in Half Moon Bay as well as developments throughout San Mateo County and neighboring Santa Clara County. Affordable housing developments in the region, as shown by the table below, typically develop at densities well above 100% of maximum density allowed due to State Density Bonus Law and other bonus density programs. Market rate developments often develop at less than 100% density, and pipeline projects in Half Moon Bay are often handicapped by residential unit allotments, particularly market rate developments.

Table C-6 identifies each site, its location, and prior use. It then notes the parcel’s land use designation and zoning before noting the units proposed on the site and its proposed density, then comparing those numbers to the maximum allowed density on the site and what percentage of the maximum density is proposed for development. Many of these sites in the City (Rows A 367
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 17 through AK) are in R-L (Residential – Low Density) and R-M (Residential – Medium Density) land use designations that are historically developed with single-family housing. Although greater density is allowed with the Local Coastal Land Use Plan (adopted in 2020), the ongoing development plans appear to have a significantly lower percentage of maximum allowed density due to this historic development pattern that is now shifting. No R-L or R-M sites parcels are identified in the Site Inventory.

Finally, the table identifies four development trends: whether the site involves housing on nonresidential zoning (A), residential zoning (B), or is proposed/eligible to be a mixed-use development (C). Finally, the table notes if the development is in a downtown area (D) like Half Moon Bay’s Town Center.
368
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 18Table C-6: Recent Development and Development Factors Key:

Development Trends:

A: Non-Residential Zonin
g; B: Residential Zonin
g; C: Mixed-Used Development Proposed/Eli
gible;
D: In a Downtown area
Project Name (if
Applicable) City Address Prior Use Land Use Desgn. Zoning Units Proposed Proposed Density (DU/AC) Max. Allowed Density (DU/AC) % of Max Density Development Trends A B C D Pipeline Projects (Table C-4)
A Seymour Street at Hwy. 1 Half Moon Bay Seymour Street at Hwy. 1 Parkin g Lot R-M
R-2 20 16 17.42 90% A B
B 565 & 575 Se
ymour Street
Half Moon
Ba
y
565 Seymour Street Vacant R-M R-1 B-1 2 2 17.42 13% A B C 650 Mill Street Half Moon Ba
y
415 Purissima Street Commercial C-G C-D 5 20 30 68% A C D D 320 Church Street Half Moon Ba
y
320 Church Street Vacant PF P-S 15 3 N/A N/A A D
E 403 Chesterfield Street Half Moon Bay 403 Chesterfield Street Vacant R-M R-1 B-2 1 6 17.42 32% B F 574 Magnolia Street Half Moon Ba
y
Magnolia Street Vacant R-M R-1 B-1 1 8 17.42 46% A B
G 433 Main Street Half Moon Ba
y
433 Main Street Commercial C-G C-D 6 17 30 56% A C D
H 700 Monte Vista Lane Half Moon Ba
y
700 Monte Vista Lane Commercial R-H C-R 6 10 30 32% A C D I 700 Block Monte Vista Lane Half Moon Ba
y
700 Monte Vista Lane Vacant R-H C-R 2 5 30 18% A C D
J 2778 Pullman
Avenue
Half Moon
Ba
y
2778 Pullman
Avenue Vacant R-L PUD 1 2 N/A N/A A B
K 698 Terrace
Avenue
Half Moon
Ba
y
698 Terrace
Avenue Vacant OS-CR R-1 B-2 1 4 17.42 21% A B
L 549 Grove Street Half Moon Ba
y
549 Grove Street Vacant R-M R-1 B-1 1 11 17.42 62% B
M 341 Myrtle Street Half Moon Ba
y
341 Myrtle Street Vacant R-M R-1 1 21 17.42 120% B
369
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 19 N 909 Grandview Boulevard Half Moon Bay 909 Grandview Boulevard Vacant R-M R-1 B-2 1 9 17.42 50% B O 336 Myrtle Street Half Moon Ba
y
336 Myrtle Street Vacant R-M R-1 B-1 1 9 17.42 49% B
P 300 Main Street Half Moon Ba
y
300 Main Street Commercial C-G C-D 10 8 30 26% A C D
Q 493 Kelly Avenue Half Moon Ba
y
493 Kelly
Avenue Vacant R-H R-3 1 7 29.04 25% B
R 655 Potter
Avenue
Half Moon
Ba
y
655 Potter
Avenue Vacant R-M R-1 1 6 17.42 32% B
S 795 Main Street Half Moon Ba
y
795 Main Street Commercial C-G C-D 2 10 30 32% A C D
T 727 Main Street Half Moon Ba
y
727 Main Street Commercial R-M C-D 1 9 30 29% C D
U 0 Miramontes
Avenue
Half Moon
Ba
y
0 Miramontes
Avenue Vacant R-M R-1 1 6 17.42 33% B
V 0 Purissima Street Half Moon Ba
y
0 Purissima Street Vacant C-G C-D 1 8 30 28% A C D
W 2411 Cabrillo Hw
y. S
Half Moon
Ba
y
2411 Cabrillo Hw
y. S Residential R-C OS-R 7 0 1 40% A B
X 8 Jenna Lane Half Moon Ba
y
8 Jenna Lane Vacant PD PUD 1 1 N/A N/A A
Y 390 Redondo Beach Road Half Moon Ba
y
390 Redondo Beach Road Residential R-M R-1 B-2 1 3 17.42 14% B Z 563 Myrtle Road Half Moon Ba
y
563 Myrtle Road Vacant R-H R-2 1 11 17.42 60% B
AA 435 Johnston Street Half Moon Ba
y
435 Johnston Street Commercial R-M C-R 1 9 30 29% A C
AB 316 Grove Street Half Moon Ba
y
316 Grove Street Vacant R-M R-1 B-1 1 11 17.42 62% B
AC 63 Guerrero
Avenue
Half Moon
Ba
y
63 Guerrero
Avenue Vacant R-M R-1 B-1 1 10 17.42 57% B
AD 419 Garcia
Avenue
Half Moon
Ba
y
419 Garcia
Avenue Vacant R-M R-1 1 8 17.42 46% B
AE 716 Monte Vista Lane Half Moon Ba
y
716 Monte Vista Lane Residential R-H R-1 B-2 1 2 17.42 12% B D 370
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 20 AF Poplar Street & 4th Half Moon Ba
y
Poplar Street & 4th Vacant R-M R-2 1 12 17.42 71% B
AG 219 Pilarcitos
Avenue
Half Moon
Ba
y
219 Pilarcitos
Avenue Vacant R-H R-3 3 17 29.04 58% B
AH 250 San Mateo Road Half Moon Ba
y
250 San Mateo Road Vacant IND-L Ind 32 17 N/A N/A A B C AI 75 Main Street Half Moon Ba
y
75 Main Street Vacant PF PUD 167 4 N/A N/A A
AJ 555 Kelly Avenue Half Moon Ba
y
555 Kelly
Avenue Residential PF P-S 40 29 N/A N/A A
AK 201-208 Carnoustie Court Half Moon Bay 201-208 Carnoustie Court Vacant PD R-1 B-2 8 6 17.42 33% B Selected 100% Affordable Developments in San Mateo and Santa Clara County Crane Place Menlo Park 1331 Crane Street Retirement Home Retirement Living Units District RLU(X) 93 99 97 102% B Firehouse Square Belmont 1300 El Camino Real Vacant Village Core VC 81 65 N/A N/A C Alma Point at Foster
Square
Foster
City
790 Alma Lane Vacant Civic Center C- M/PD/SHO 66 79 35 189% C Eagle Park Mountain View 1701 West El Camino Real Commercial Village Center P 67 137 80 171% A C D Wilton Court Palo Alto 3703 El Camino Real Commercial Neighborhood Commercial CN 59 128 20 641% A C D Selected Market Rate Developments in San Mateo and Santa Clara County Edgewood Plaza Palo Alto
2170 W Bayshore Road
Commercial Neighborhood Commercial CN 10 11 20 53% A C
371
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 21 210-260 View Street Mountain View 210 View Street Commercial View/Hope Street Residential Transition Area
P(19) 8 14 40 34% A C
12370 SaratogaSunnyvale Saratoga
12370 Saratoga Sunnyvale Road
Commercial Commercial Neighborhood CN 20 7 20 37% A C
Cypress Point Moss Beach Carlos Street and Sierra Street Vacant Medium Density Residential PUD- 140/CD 71 7 7 93% A 372
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 22 The Realistic Capacity factors assigned to units in the site inventory are based on site type. They are assigned a factor based on historical development patterns as well as on the incentives provided in Half Moon Bay’s housing plan, particularly modified development standards (Program 1-2), developing housing on publicly owned lands (Program 4-8), removal of constraints (Program 6-4), and revisions to the Residential Dwelling Unit Allocation System (Program 6-8).

Potential development on nonvacant sites is described on a site-by-site basis in the site descriptions, beginning on page C-25.

Typical Densities: Development potential based on existing or approved residential developments at a similar affordability level in the jurisdiction. Typical Densities were identified based on the affordability level (very low, low, moderate, above moderate).

Development is typically built above allowed densities at the lower and moderate-income levels in San Mateo County. According to data collected by ABAG/San Mateo County, 14 lower-income projects were built on average at 107% of maximum allowable density. 19 moderate-income projects were built at an average of 125% of maximum allowable density. A typical densities factor of 97% for very low, 90% for low, and 80% for moderate can be considered conservative and account for lower land values in Half Moon Bay relative to the more densely populated areas of the County.

Infrastructure Adjustment: This factor considers the current or planned availability and accessibility of sufficient water, sewer, and dry utilities. No Infrastructure Adjustment Factors are necessary because 11 of 12 Housing Opportunity Sites were included in the LCLUP buildout assessment wherein infrastructure was found to be substantially available through the 2040 planning horizon. Density bonus assumptions within Town Center were also included in the buildout assessment for several hundred units to account for the development impacts of the Housing Opportunity Site not included in the LCLUP’s buildout assessment.

Environmental Adjustment: Site-specific environmental conditions that may impact realistic buildout capacity are also factored in.

Eleven of the 12 Housing Opportunity Sites have no identified environmental site constraints.

However, portions of Site #1, the City-owned property at 880 Stone Pine Road, include mapped environmentally sensitive habitat areas (ESHA). Previous studies have identified that approximately 4 acres of this 20.66-acre parcel are suitable for housing without endangering the critical habitat and in compliance with all buffer requirements imposed by the various resource agencies and the City’s own certified LCP. This adjustment factor is identified by noting that 4 acres of the site are usable for residential development (see Table C-9: Sites for Lower-Income RHNA, later in this section). However, to make a conservative estimate based on the likely buildout for Site #1, a further 50% Environmental Adjustment on top of the 4-acre assessment was applied.

The “Other” category is reserved for Site #12. The zoning on the parcels making up Site #12 is PUD, which does not have a set minimum residential density. Neither does the LCLUP/General Plan Planned Development land use designation. Buildout in planned development areas is 373
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 23 established through the master planning process. In this case, a residential density of one unit per parcel can be applied as this is the buildout established by the California Coastal Commission’s approved coastal development permit and associated legal settlement. To best capture the unique development assumptions of this site, adjustment factors were set at 1 for all categories.

Table C-7: Adjustment Factors for Land Use Controls, Realistic Capacity, Infrastructure, and Environment
Site Types
Adjustment Factors
Land Use
Controls
Realistic
Capacity Infrastructure Environmental Total
TC and
TC w/ WHO .9 .85 1 1* .765
WHO .95 .97 1 1 .922
MHP .66 .75 1 1 .495
Other 1 1 1 1 1
Source: City of Half Moon Bay
*Site #1 has an Environmental Adjustment Factor of .50, giving it a total adjustment of .383.

Table C-8: Adjustment Factors for Typical Densities
Affordability Level Typical Densities Adjustment Factor Very Low 0.97
Low 0.9
Moderate 0.8
Above Moderate/”Other”* 1.0
Source: City of Half Moon Bay
*Only Site #12 is allocated for above moderate-income levels.

In the Housing Opportunity Sites Summaries further below in this report, Diagrams C-1 through C-12 present site-by-site specifics, the rationale for, and the application of these adjustment factors.

Sites Analysis
Of the 12 sites in the Site Inventory, 6 are non-vacant. For these sites, HCD requires demonstration of the potential and likelihood of additional development within the planning period based on:
374
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 24 • The extent to which existing uses may constitute an impediment to additional residential development
• Past experience with converting existing uses to higher-density residential development • Current market demand for the existing use
• Any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development • Development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites In addition, the Housing Element must either demonstrate that non-vacant sites accommodate less than 50 percent of the lower-income RHNA or include adopted findings based on substantial evidence that the existing uses are not impediments.

Finally, the Housing Element must include a housing replacement program if any non-vacant sites that include residential units are or were occupied by or subject to affordability agreements for lower-income households within 5 years. However, no non-vacant Housing Opportunity Sites include such units, so the applicable program is not necessary.

Environmental Constraints
The “Housing Opportunity Sites Summaries” section provides site-by-site descriptions of potential environmental constraints. Half Moon Bay is entirely within the Coastal Zone, which includes attendant issues such as flooding, sea level rise, and environmentally-sensitive habitats.

Additional environmental analysis may be required for some projects, but none of the City’s housing opportunity sites are located in areas with these unique constraints. There are no other known conditions that preclude development on identified sites, such as shape, easements, Williamson act contracts, contamination, coastal policies, and property conditions.

Potential and Likelihood of Additional Development
The existing uses on the 6 non-vacant sites do not present substantial impediments to higherdensity residential development on the sites, as described in the next section, Housing Opportunity Sites Summaries.

Percentage of Lower-Income RHNA Accommodated on Non-Vacant Sites There are 285 units in the lower-income RHNA categories for Half Moon Bay. Of these units, 245 (86%) are provided via Pipeline Projects, ADUs, or units on Vacant Sites. Only 40 units (14%) are remaining to be accommodated on non-vacant sites. Therefore, findings are not required to be adopted in this Housing Element.
375
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 25 Table C-9: Extra Scrutiny Analysis
Type Lower-Income RHNA Units
RHNA 6 Total 284
Pipeline/ADU/Vacant Site Allocation 277
Total Lower-Income Units: 245
Pipeline Projects 87
ADUs 68
Vacant Sites 90
% of RHNA 6 Total 86%
Source: City of Half Moon Bay
Housing Opportunity Sites Summaries
Site 1. 880 Stone Pine Road
Site Description: In 2024, construction of permanent affordable housing began under an Emergency Coastal Development Permit in response to housing needs of displaced farmworkers from the January 2023 shooting that took place on two Coastside farms. Additional information is provided in this section about the City and County of San Mateo’s joint effort to provide long term housing on this site. This City-owned infill site is located at the terminus of Stone Pine Road near the City’s eastern boundary within the Town Center and Town Boulevard visual resource area. The topography is gently sloping from north to south with additional grading around an abandoned agricultural irrigation pond. Surrounding land uses include Highway (HWY) 92 to the north with the Hilltop Mobile Home Park and the Half Moon Bay High School emergency access road); Spanish Town mixed-use commercial/light industrial businesses to the east, Pilarcitos Creek to the south, and the Cypress Cove neighborhood and another portion of the Hilltop Mobile Home Park to the west.

In 2020, the City purchased this approximately 22-acre site for its Public Works Corporation Yard.

It had not been included in the WHO sites in the LCLUP update based on severe constraints imposed by very sensitive habitat constraints based on the advice of the City’s biologist and coordination with Coastal Commission staff. However, in 2022, the City issued a coastal development permit for improvements to the Corporation Yard that included detailed plans for establishing a “conservation corridor” to protect special status California red-legged frogs (CRLFs) that had been documented to have used the site for breeding and dispersal. The corridor is designed to allow safe movement for individual CRLFs, as well as federally protected San Francisco garter snakes (SFGSs), between the agricultural pond and Pilarcitos Creek (see Diagram C-1). In addition to the Corporation Yard improvements, the conservation corridor was subject to CEQA review and entitled as part of the coastal development permit. Construction commenced in 2022 and continued into 2023.
376
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 26 In the aftermath of the tragic January 23, 2023 mass shooting incident, San Mateo County and the City conducted inspections of the two farms where the shootings took place and discovered substandard housing conditions at both sites. Given the poor and unsafe condition of units and use of non-habitable structures, all units were “red-tagged”, and notices were issued precluding re-habitation.

Immediately following the incident, the County provided emergency housing and other direct assistance to displaced households, which was temporarily supplemented by support from AirBNB.org. Abode Services, a Bay Area based non-profit focused on ending homelessness, was hired by the County to facilitate master lease agreements, ultimately leasing temporary units for 19 displaced households. The County, City, and local non-profits worked collaboratively to identify units for each displaced household, and through the generosity of local property owners, all were able to remain housed on the Coastside.

Since the incident, the City and County have convened to reconcile how our agencies could work to put the lives of 19 farmworker households back together while addressing the needs of the countless other farmworker households that face housing quality and quantity challenges. Given the limited inventory of housing units on the Coast, and the high cost of real estate, a new development of affordable housing to support these and other farmworkers became the preferred approach. The City-owned property at 880 Stone Pine Road became the focus of efforts given its proximity to downtown, schools, shopping, transportation, and social services. With the location identified and significant funding secured, the City and County are jointly working to deliver a 47-unit affordable manufactured home neighborhood at 880 Stone Pine Road. With support of the California Coastal Commission, the City issued an Emergency Coastal Development Permit (Emergency CDP) in December of 2023, which allowed San Mateo County to immediately commence bidding work on the project. Construction began in March 2024 under the authorization of the Emergency CDP, and the Planning Commission recently approved the required follow up CDP on October 22, 2024. This project, referred to as Stone Pine Cove, is targeted for completion in Spring 2025. More information on the development can be found at the City’s website at: www.hmbcity.com/stonepinehousing.

377
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 27 Diagram C-1: Site 1. 880 Stone Pine Road
Site Area:

Gross: 21.66 AC
Net: 4.5 AC
LCLUP/GP: PF
Zoning: U-R
Rezone to: PS with WHO
Base Density: Per pending
rezone to PS with WHO.

Source: City of Half Moon Bay and SWCA
Current Use: City Public
Works corporation yard;
conservation corridor and
buffers; housing site is
vacant.

Affordability Assumptions:

Very Low
Existing Uses: Housing site is
vacant.

Constraints: Needs WHO
land use designation and
zoning, ESHA, dam
inundation zone, HWY 92
noise, site access.

Access to Resources:

Town Center location, walk to
schools, stores, and services.

Near bus stops.

Net Acreage: 4.5 ac. Max. Density: 30 DU/AC Max. Buildout: 135 units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor

0.90 0.85 .97 1 .50 .371
Realistic Yield: 50 units
The site currently supports two primary uses:

City Corporation Yard: Roughly a third of the site is actively used as the City’s Public Works Department Corporation Yard.

Habitat Conservation Areas: The habitat conservation areas are extensive and precisely mapped. They include the agricultural pond; Pilarcitos Creek; habitat buffers from the extent of the pond (wetlands) and the creek (riparian); and the conservation corridor. The 378
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 28 conservation corridor establishes safe passage for special status CRLF and SFGS between the pond and the creek. A multi-use path within a defined access easement parallel to Pilarcitos Creek, within its riparian buffer, is planned as a future use. Upon complete installation of the conservation corridor, which primarily consists of specifically aligned exclusionary fencing and wildlife tunnels under the primary access road, the remaining undeveloped portion of the site will become safe to develop from the perspective of environmental resource protection.

The adjustment factors take into account the environmental constraints on the site due to the Corp Yard and the conservation areas (50% Environmental Controls factor). The site is within the Town Center area, where there has been substantial residential redevelopment and for which the Housing Element contains programs incentivizing further residential development. For this reason, the site is assigned a Realistic Capacity adjustment factor of 85%.

Owner/Developer Interest: The City has determined that approximately 4 acres of the site, west of the Corporation Yard, and not within designated habit or buffer areas are suitable for affordable housing development. Following discussions at several public meetings, City Council indicated that the site should be prioritized in the Cycle 6 Housing Element inventory. The City has continued to evaluate additional site constraints including risk associated with potential flooding from Pilarcitos Creek or in the event of failure of the Pilarcitos dam (the site is in the Pilarcitos dam inundation zone). City consultants reviewed buildout options and presented the site to affordable housing developers for feedback. Buildout varies significantly depending on the housing type that is pursued.

Originally, the City considered the site for multi-family low-rise apartment development, which could yield up to 100 units; however, following the January 23, 2023, shooting on two Coastside farms, recognition that a faster buildout with manufactured housing units in a range of sizes would be the best approach to serve immediate needs. In a mobile home format, which is lower density, buildout is up to about 50 units. The County of San Mateo has been collaborating with the City to act as the property developer. The County has prepared conceptual site plans and the City has been supporting the County’s applications for grant funding for farmworker housing.

This opportunity site has potential to be the first buildout in the Cycle 6 Housing Element.

Agricultural land use is a permitted use on this property, and the City’s LCP and the Coastal Commission consider farmworker housing to be an agricultural use. Thus, if the full buildout is for farmworker housing, no further LCP amendment would be required. However, if buildout expands beyond farmworker housing, such as for lower-income service workers, an update to add the WHO combining land use designation and zoning will be required.

At the time of the Housing Element update, the City was conducting community engagement to gather input about concerns and hopes for site development. From that effort, traffic, emergency vehicle access, ongoing oversight and maintenance of future development, and other neighborhood compatibility concerns were voiced. The City has committed to studying and addressing these matters, as feasible, via thoughtful site planning. Community engagement also 379
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 29 indicated that there is strong interest in having site development move forward as quickly as possible.

Site 2. 498 Kelly Avenue
Site Description: The Hatch Elementary School is owned and operated by the Cabrillo Unified School District (CUSD) and is located within the and Town Boulevard visual resource area on the southwest corner of Kelly Avenue and HWY 1. The property is generally flat and can be accessed from multiple sides. Surrounding uses include multi-family residential and commercial uses to the north, Cunha Intermediate School and commercial uses to the east, and single-family residential development to the south and west.

380
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 30 Diagram C-2: Site 2. 498 Kelly Avenue
Site Area:

Gross: 15.36 AC Net: 2.4 AC
LCLUP/GP: PF with WHO
Zoning: PS
Base Density: Per WHO
Source: City of Half Moon Bay GIS.

Current Use: Public K-6 grade
school, CUSD offices and
maintenance yard, and
ancillary uses.

Affordability Assumptions:

Low
Constraints: Existing
development (maintenance
yard and offices) would need
to be relocated, HWY 1 noise
Access to Resources:

Immediately adjacent to the
Town Center, walk to schools,
stores, services, park, and
multi-use path. Near bus
stops.

Net Acreage: 2.4 Acres Max. Density: 30 DU/AC Max. Buildout: 72 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor

0.95 0.97 0.90 1 1 0.829
Realistic Yield: 60 Units
The site takes advantage of the Workforce Housing Overlay, an overlay zone that incentivizes residential development – particularly for workforce housing as intended for this site. This overlay zone has been used to develop residential housing recently, and is further incentivized by the policies and programs in this Housing Element. For this reason, the site is assigned a Realistic Capacity adjustment factor of 97%.
381
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 31 Owner/Developer Interest: In 2012, the District deemed the northern portion of the Hatch site underutilized and surplus. Currently, the District is studying the property for affordable housing for District faculty and staff and refers to the project as the “District Office Site”. The District’s preliminary site plan includes 60 multi-family housing units on the north end of the property.

CUSD and City staff have met on multiple occasions to review development options and permitting processes. The District submitted a preliminary application in May 2023 to receive early feedback about objective design requirements, e.g., emergency vehicle access and parking.

The District was planning to conduct community outreach in fall 2023 and submit a formal application at that time. The proposed 60-unit buildout conforms to the WHO land use designation for a project utilizing a density bonus, for which this project would qualify.

The City will continue to work with the District to continue community engagement and help identify interested developers, as well as mitigate the impacts of relocating existing district office uses. This collaboration could include facilitating development on the site as appropriate and applicable, including potentially incentivizing development with fee waivers or prioritized review.

Development shall be compliant with the Surplus Lands Act, if applicable. If there is no interested developer identified by mid-cycle (end of December 2027), then the City will identify alternative sites, as necessary, to address any RHNA shortfall. If an interested developer is identified, the City will collaborate in order to complete development entitlements by 2029 and complete development by the end of the Housing Element planning period (2031).

Site 3. 300 Block Church Street
Site Description: This vacant infill site is centrally located within the Town Center and heart of Heritage Downtown. The site is flat and not encumbered by any coastal resource protection requirements. Surrounding uses include the Creekside residential development to the north (a Pipeline Project), low-density residential development to the east, Our Lady of the Pillar Catholic Church to the south, and the City of Half Moon Bay Ted Adcock Community Center to the west.

The site is also proximate to the City’s 555 Kelly Avenue farmworker housing development site (another Pipeline Project).

Owner/Developer Interest: The property is owned by the Archdiocese of San Francisco and used by the Our Lady of the Pillar parish from time to time for temporary uses. The site is in the Public Facilities and Institutions land use designation and Public Service zoning, with the WHO. In the LCLUP update, the WHO was specifically applied to this centrally located and highly developable site to facilitate an affordable housing project for extremely low-, very low-, and low-income households. The City estimates a maximum buildout of 70 multi-family residential units.

When the City embarked on identifying opportunities sites for the Cycle 6 Housing Element, City staff has met with the owner (Archdiocese of San Francisco) who indicated interest in future affordable residential development on this property, but acknowledged that the local Parrish would be a part of the conversation. At the time, numerous church parishioners expressed interest in the owner partnering with a non-profit housing developer to build affordable housing on this mostly unused property. A multi-use building that includes childcare, preschool, and/or 382
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 32 other supportive uses were identified as possible uses - to integrate into site development to further support interests expressed by various parishioners.

In mid-2023, an on-site independent school, Our Lady of the Pillar Academy (OLP Academy), began operating within existing parish buildings. In 2024, the local Pastor and Archdiocese expressed their support for utilizing Site 3 for a K-8 school developed and operated by OLP Academy. Identification of the site as an Opportunity Site does not restrict the Church or a private party from seeking to develop the parcel for any other allowable use. In 2024, the City received letters from the Pastor of Our Lady of the Pillar Catholic Church and from the San Francisco Archdiocese indicating their intention to use Site 3 for quality religious education. The City has not received a formal Coastal Development Permit application for the development of a school or other building(s) on the vacant site, but acknowledges the recent support and interest to build a school and respects the rights of Our Lady of Pillar or a private party to pursue a private school.

The City is retaining this site in the Opportunity Sites section as an acknowledgement that Cycle 8 represents an 8-year horizon and priorities of the parish and its leadership may (or may not) change. It also acknowledges an opportunity to incorporate a mixed-use approach with housing for teachers, service workers, and other populations outlined in the Workforce Housing Overlay should the parish choose to pursue. Again, the owner is not obligated in any way to pursue housing on this site.

383
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 33 Diagram C-3: Site 3. 300 Block Church Street
Site Area:

Gross: 1.9 AC, Net: 1.55 AC
LCLUP/GP: PF with WHO
Zoning: PS
Base Density: Per WHO
Source: City of Half Moon Bay GIS.

Current Use: Undeveloped
field, used for parking or
church functions.

Affordability Assumptions:

Very Low
Constraints: Owner’s
interest in all potential uses
may affect timing.

Access to Resources: Within
Town Center, walk to schools,
stores, services, community
center, library, parks. Near
bus stops.

Net Acreage: 1.55 Acres Max. Density: 45 DU/AC Max. Buildout: 70 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor

0.9 0.85 0.97 1 1 0.742
Realistic Yield: 52 Units
Site 4. 0 Block Stone Pine Road
Site Description: This vacant infill site is located close to Main Street in the North Downtown region of the Town Center. The site slopes gently down from east to west. Adjacent land uses include commercial development to the north, Cypress Cove townhouse neighborhood to the east, Stone Pine Shopping Center and John L. Carter Memorial Park to the south, and small commercial businesses to the west. Although near Pilarcitos Creek, the site is not within any required buffer areas.
384
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 34 Diagram C-4: Site 4. 0 Block Stone Pine Road
Site Area: 0.48 AC LCLUP/GP: C-G
Zoning: C-G
Base Density: 30 DU/AC
Source: City of Half Moon Bay GIS.

Current Use: Vacant, outside
storage from time to time.

Affordability Assumptions:

Moderate
Constraints: Gently sloping
site may require low retaining
walls. May need parking
exception, or code update, to
improve build-out yield.

Access to Resources: Within
Town Center, walk to schools,
stores, services, community
center, Main Street. Near bus
stops.

Net Acreage: 0.48 Acres Max. Density: 29.04 DU/AC Max. Buildout: 14 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor

0.9 0.85 0.8 1 1 0.612
Realistic Yield: 9 Units
Owner/Developer Interest: The City has an established relationship with the owner and is currently leasing this site for storage of equipment related to a local park improvement. Housing developers, both for-profit and non-profit, have expressed strong interest in the site in recent years. One developer prepared a site plan with 11 prefabricated units arranged around a central community garden with a shared parking area. The concept, viewed favorably by City staff, would have required a parking exception. Program 1-2 addresses this constraint. Study of this site and the preliminary design contributed to the City’s understanding of the need for more flexible parking standards for sites like this one.
385
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 35 Site 5. 101 Canada Cove Avenue
Site Description: The site consists of 4 acres of vacant land next to an existing 55 and over modular home community, Canada Cove. The site is predominately flat and benefits from being at a lower grade than HWY 1 for sound protection. Adjacent uses include medium-density residential development to the north, equestrian and agricultural uses to the east, and the Canada Cove mobile home park to the south and west. Located within the Town Boulevard visual resource area, near the southern city limit, the site will benefit from the City’s plan to increase bike and pedestrian access to the Town Center via multi-use pathways parallel to HWY 1. A traffic light on the northeast corner of the property allows for safe crossing and access to bus stops on both sides of HWY 1 near the property. The Project will require a biological resource evaluation as the project site is a large parcel of land that has not been developed.

Diagram C-5: Site 5. 101 Canada Cove Avenue
Site Area: 4.12 AC LCLUP/GP: MHP
Zoning: MHP
Base Density: 21.78 DU/AC
Source: City of Half Moon Bay GIS.

Current Use: Vacant
Affordability Assumptions:

Low
Constraints: LCP Town
Boulevard Visual Resource
area; HWY 1 noise.

Access to Resources: Near
bus stop and limited
commercial services; walking
distance to Miramontes Pt.

Road public beach access.

Net Acreage: 4.12 Acres Max. Density: 21.78 DU/AC Max. Buildout: 90 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor

0.66 0.75 0.9 1 1 0.495
Realistic Yield: 40 Units
386
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 36 Owner/Developer Interest: The owners of the site have been in contact with the City to explore options to expand the existing modular home community and/or similar use. Manufactured homes tend to be low-rise, and thus the visual resource corridor constraint is alleviated by the anticipated development type.

Site 6. 740 Purissima Street
Site Description: This is a half-acre under-utilized infill site within Town Center. The site is predominately flat. Adjacent uses include the Half Moon Bay Library to the north, commercial and residential development to the east, and the Amesport Landing townhouse neighborhood to the south and west. The front of the property (east side) is developed with five multi-family units which represent legal non-conforming development in the R-2 zoning district. This development covers approximately 50% of the property.

Diagram C-6: Site 6. 740 Purissima Street
Site Area: 0.55 AC LCLUP/GP: Res-High
Zoning: R-2 Rezone to: R-3
Base Density: 17.42 DU/AC
Source: City of Half Moon Bay GIS. Current Use: Multi-family residential
Affordability Assumptions:

Moderate
Constraints: Relocation
requirements could hinder
full redevelopment to achieve
a higher yield; requires
rezoning to R-3.

Access to Resources: Within
Town Center, walk to schools,
stores, services, community
center, library, parks. Near
bus stops.

Net Acreage: 0.55 Acres Max. Density: 29 DU/AC Max. Buildout: 16 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor

0.9 0.85 0.97 1 1 0.742
Realistic Yield: 12 Units
387
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 37 The site is within the Town Center area, where there has been substantial residential redevelopment and for which the Housing Element contains programs incentivizing further residential development. For this reason, the site is assigned a Realistic Capacity adjustment factor of 85%.

Owner/Developer Interest: The property could be completely redeveloped or could include development of the vacant rear (west) portion of the site. Rezoning to R-3 is anticipated in the LCLUP, and property owner representatives have reached out to the City during and after the LCLUP update process supporting the land use designation change from Residential-Medium to Residential-High. The City has also been contacted by non-profit housing developers interested in purchasing the property. This could help ensure that existing renter households are provided with housing options in the case of full site redevelopment. The City is continuing to work with the property owner and interested housing developers to redevelop the property while retaining existing renter households. This could necessitate only partial redevelopment of the site. The City continue to work with interested parties with the expectation of having a formal development application by the end of December 2027.

Site 7. 895 Main Street
Site Description: This underutilized Town Center site is predominantly flat and located on a corner parcel. Adjacent uses include residential and low-rise commercial development on all sides with Coastside Senor Housing development and center to the south. The South Downtown location emphasizes residential uses, including on Main Street.

388
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 38 Diagram C-7: Site 7. 895 Main Street
Site Area: 0.21 AC LCLUP/GP: C-G
Zoning: C-D
Base Density: 29.04 DU/AC
Source: City of Half Moon Bay GIS.

Current Use: Single-family
home
Affordability Assumptions:

Moderate
Constraints: Retention of the
single-family home limits
yield.

Access to Resources: Within
Town Center, walk to schools,
stores, services, Poplar
Beach, and California Coastal
Trail. Near bus stops.

Net Acreage: 0.21 Acres Max. Density: 30 DU/AC Max. Buildout: 6 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor

0.9 0.85 0.8 1 1 0.612
Realistic Yield: 4 Units
The site is within the Town Center area, where there has been substantial residential redevelopment and for which the Housing Element contains programs incentivizing further residential development. For this reason, the site is assigned a Realistic Capacity adjustment factor of 85%.

Owner/Developer Interest: This is one of the smaller partially vacant sites at slightly less than a quarter acre; however, in meeting with City staff on several occasions, the owner has shared strong interest to increase the number of housing units on the site. The owner is exploring two options: 1.) Total site redevelopment with a new mixed-use development utilizing the maximum allowed density, which could potentially yield six units without a density bonus, and 9 units with the maximum density bonus; or 2.) Retention of the existing single-family home and infill with an “ADU demonstration” project adding up to five small, detached units. The property owner is involved with an ADU pre-fabrication company and is interested in providing a cottage court living environment on the site. City staff has also researched opportunities for affordable housing 389
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 39 funding from the San Mateo County farmworker housing forgivable loan program should such units be reserved for qualifying households. The owner wanted the site to be included in the Cycle 6 inventory. Due to the existing site constraint of the single-family home, the City made a conservative assumption about realistic yield. The City continue to work with interested parties with the expectation of having a formal development application by the end of December 2027.

Site 8 - 500 Block Poplar Street
Site Description: This rectangular vacant infill site is in the Town Center. Located within the Town Boulevard visual resource area, on the southwest corner of HWY 1 and Poplar Street, the site is predominantly flat. Surrounding uses include single-family and duplex units to the north; vacant sites to the east and south; and a single-family residential neighborhood on the west side of HWY

1. The site is comprised of two parcels in single ownership.

Owner/Developer Interest: City staff met with the property owner during the LCLUP update, who was very amenable to the land use designation change from Residential-Medium to Residential-High. The owner and staff studied concept build-out options in compliance with the future rezoning to the R-3 district for nine units without a density bonus. Two- and three-story approaches with surface and/or tuck-in parking were considered. The owner also inquired about the potential for use of the undeveloped Fourth Avenue right-of-way, which could provide access and/or be vacated by the City to increase site area. Additional vacant sites on Poplar Street, as well as to the south on Metzgar Street which backs up to the site, make for potential lot consolidation. However, because these other sites are in different ownerships, the City assumed individual site development to not impose a constraint on any of the Housing Opportunity Sites for lot consolidation.

390
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 40 Diagram C-8: Site 8 - 500 Block Poplar Street
Site Area: 0.32 AC LCLUP/GP: Res-High
Zoning: R-2, Rezoning to: R-3
Base Density: 17.42 DU/AC
Source: City of Half Moon Bay GIS.

Current Use: Vacant
Affordability Assumptions:

Moderate
Constraints: HWY 1 noise.

Access to Resources: Within
Town Center, walk to
schools, stores, services,
Poplar Beach, and California
Coastal Trail. Near bus stops.

Net Acreage: 0.32 Acres Max. Density: 29.04 DU/AC Max. Buildout: 9 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra. Controls Enviro.

Controls
Total Factor

0.9 0.85 0.8 1 1 0.612
Realistic Yield: 5 Units

391
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 41 Site 9. 604 Poplar Street
Site Description: This rectangular infill site is in the Town Center. It is predominantly flat.

Surrounding uses include single-family and duplex units to the north; vacant sites to the east, south, and west; and a single-family residential neighborhood on the west side of HWY 1. The site is comprised of three parcels in single ownership, and a single-family home sits on the middle parcel.

Diagram C-9: Site 9. 604 Poplar Street
Site Area: 0.32 AC LCLUP/GP: Res-High
Zoning: R-2, Rezoning to: R-3
Base Density: 17.42 DU/AC
Source: City of Half Moon Bay GIS
Current Use:

Single-family home
Affordability Assumptions:

Moderate
Constraints: Retention of
single-family home reduces
build-out potential. Owner
has no immediate interest.

Access to Resources: Within
Town Center, walk to schools,
stores, services, Poplar
Beach, and California Coastal
Trail. Near bus stops.

Net Acreage: 0.32 Acres Max. Density: 29.04 DU/AC Max. Buildout: 10 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor

0.9 0.85 0.8 1 1 0.612
Realistic Yield: 5 Units
The site is within the Town Center area, where there has been substantial residential redevelopment and for which the Housing Element contains programs incentivizing further residential development. For this reason, the site is assigned a Realistic Capacity adjustment factor of 85%.

Owner/Developer Interest: The owner has had past communications with the City about housing development throughout the City and in this neighborhood. The pending rezoning of R3 will improve such prospects. As with site #8, the undeveloped Fourth Avenue right-of-way could 392
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 42 provide access and/or be vacated by the City to increase site area. Additional vacant sites on Poplar Street, as well as to the south on Metzgar Street which backs up to the site, make for potential lot consolidation. However, because these other sites are in different ownerships, the City assumed individual site development to not impose a constraint on any of the Housing Opportunity Sites for lot consolidation. In 2024, the owner provided notice to the city that there is no immediate intent to redevelop the property. Due to the proximity of this property to sites 8, 10, and 11 with R-3 zoning, the City is retaining as an Opportunity Site. The City continue to work with interested parties with the expectation of having a formal development application by the end of December 2027.

Site 10. 600 Block Poplar Street
Site Description: This rectangular infill site is in the Town Center. It is predominantly flat.

Surrounding uses include single-family and duplex units to the north and east, and vacant sites to the south and west. The site is comprised of four parcels in single ownership.

Diagram C-10: Site 10. 600 Block Poplar Street
Site Area: 0.4 AC LCLUP/GP: Res-High
Zoning: R-2, Rezoning to: R-3
Base Density: 17.42 DU/AC
Source: City of Half Moon Bay GIS.

Current Use: Vacant
Affordability Assumptions:

Moderate
Constraints: No unusual
conditions.

Access to Resources: Within
Town Center, walk to schools,
stores, services, Poplar
Beach, and California Coastal
Trail. Near bus stops.

Net Acreage: 0.4 Acres Max. Density: 29.04 DU/AC Max. Buildout: 11 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor

0.9 0.85 0.8 1 1 0.612
Realistic Yield: 6 Units
393
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 43 Owner/Developer Interest: For several decades, this owner has developed numerous infill sites throughout the City and continues to actively develop sites that have been in family ownership for many years. For site #10, the owner favorably acknowledged the increased buildout potential from the LCLUP update which will lead to rezoning to the R-3 district. Additional vacant sites on Poplar Street, as well as to the south on Metzgar Street which backs up to the site, make for potential lot consolidation. However, because these other sites are in different ownerships, the City assumed individual site development to not impose a constraint on any of the Housing Opportunity Sites for lot consolidation.

Site 11. 940 Main Street
Site Description: This nearly two-acre infill site is developed with one single-family home on the east end of the property; most of the lot is vacant. The site comprises the southern side of an entire City block. The home is included in the City’s historic resources inventory, the eastern portion containing the historic home will be parceled off. The site is in the South Downtown portion of the Town Center, within the Town Boulevard visual resource area, and mostly flat.

Surrounding uses include vacant sites and residential development to the north, the Coastside Senior Housing development and center to the east, and residential development to the south and across HWY 1 to the west.

394
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 44 Diagram C-11: Site 11. 940 Main Street
Site Area: 1.91 AC LCLUP/GP: Res-High
Zoning: R-2, Rezoning to: R-3
Base Density: 17.42 DU/AC
Source: City of Half Moon Bay GIS.

Current Use: Single-family
home, mostly vacant.

Affordability Assumptions:

Very Low
Constraints: House is on
historic inventory, HWY 1
noise on the west end of the
site.

Access to Resources: Within
Town Center, walk to
schools, stores, services,
Poplar Beach, and California
Coastal Trail. Near bus stops.

Net Acreage: 1.91 Acres Max. Density: 29.04 DU/AC Max. Buildout: 55 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra. Controls Enviro.

Controls
Total Factor

0.90 0.85 0.97 1 1 0.742
Realistic Yield: 41 Units
The site is within the Town Center area, where there has been substantial residential redevelopment and for which the Housing Element contains programs incentivizing further residential development. For this reason, the site is assigned a Realistic Capacity adjustment factor of 85%.

Owner/Developer Interest: The site has been on and off the market for a number of years. The owners obtained approval for an 11 duplex lot subdivision, including four affordable housing units as required by the City’s Below Market Rate (BMR) Ordinance. However, the subdivision was never recorded. The R-3 rezoning will work well for multi-family development on a single lot; thus, the lack of completion of the subdivision has turned out to be fortuitous. This site was included in both the Cycle 4 and 5 Housing Elements. Rezoning should significantly diminish past constraints associated with the previously approved duplex subdivision. The existing historic home could potentially be moved closer to Main Street to further improve residential yield; however, it is not necessary for realistic yield buildout to move the existing home. City staff have 395
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 45 discussed adaptive reuse of the home with prospective developers for childcare, supportive services, or a community space.

An affordable housing developer has approached the owners to purchase the property. The City cannot disclose more details about this opportunity to avoid disrupting active sales negotiations.

The City continues to work with interested parties with the expectation of having a formal development application by the end of December 2027.

Site 12. Pacific Ridge Phases 2 and 3
Site Description: This site is located at the terminus of Terrace Avenue at the eastern limits of the city boundary. It slopes downward from east to west. Surrounding uses include protected open space to the north, public open space and predominately undeveloped hillsides to the east, Half Moon Bay High School to the south, and the Highland Park residential neighborhood to the west. This site includes 44 parcels in the Pacific Ridge residential subdivision. The subdivision is made up of three phases. Phase 1 is sold and developed. The City approved Final Maps for Phases 2 and 3, and all infrastructure, including streets and utilities, has been installed.

Owner/Developer Interest: Past litigation settlement and a coastal development permit issued by the California Coastal Commission specifies that development of each parcel is for one singlefamily residence; therefore, site #12 is assumed to develop with 44 above moderate-income single-family homes for the purposes of the Site Inventory. The property owner is actively seeking to sell Phases 2 and 3 to a master builder, as had been done for Phase 1.

396
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 46 Diagram C-12: Site 12. Pacific Ridge Phases 2 and 3
Site Area: ~ 17 AC LCLUP/GP: PD
Zoning: PUD
Base Density: per PUD
Source: City of Half Moon Bay GIS.

Current Use:

Vacant subdivided lots
Affordability Assumptions:

Above Moderate
Constraints: Limited buildout
options due to settlement
agreement and Coastal
Commission approved coastal
development permit. Site
drainage must be carefully
maintained; slope failure
above the site occurred in
recent years.

Access to Resources: Near
Town Center and Half Moon
Bay High School.

Net Acreage: 17.37 Acres Max. Density: 1 DU/AC Max. Buildout: 44 Units Adjustment Factors:

Land Use
Controls
Realistic
Capacity
Typical
Densities
Infra.

Controls
Enviro.

Controls
Total Factor
1 1 1 1 1 1
Realistic Yield: 44 Units

397
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 47 Infrastructure
The LCLUP update included an extensive assessment of infrastructure capacity for water supply and wastewater treatment. Water supply and wastewater treatment capacity were found to be adequate for the 2040 planning horizon. The LCLUP assumed two RHNA cycles, assuming that RHNA 6 and 7 would likely be higher than for Cycle 5, while still needing to fit within the Measure D residential growth limitation. Cycle 6 RHNA, as represented by the Pipeline Projects, Opportunity Sites, and accessory dwelling units was fully accounted for in these buildout analyses. The LCLUP assumed buildout of additional sites for both commercial and residential development to establish a conservative assessment. Despite the adequacy of capacity, some limitations must be acknowledged as constraints. These were discussed in the Technical Report Appendix B – Constraints and key findings are highlighted below. Electricity is also considered.

Water Supply: Following the LCLUP update, the Coastside County Water District completed its 2020 Urban Water Management Plan (UWMP). The UWMP concluded that water supply was adequate for normal (non-drought) years; however, supply shortfalls are projected in single dry and multiple dry years with implementation of the Bay-Delta Plan Amendment. These projected shortfalls must be addressed through the District’s Water Shortage Contingency Plan which requires serious conservation efforts. The Water District is also working to establish additional water sources.

Wastewater Treatment Capacity: Wastewater treatment capacity was found to be adequate, provided that continued investment in reduction inflow and infiltration (I&I) to maintain capacity during wet weather conditions. The City continues to fund Capital Improvement Program projects to improve the wastewater conveyance system to reduce I&I, year after year.

Electricity: Development allowed under the Cycle 6 Housing Element, in combination with cumulative development (residential and non-residential) will increase electricity demand. development projects would be required to comply with applicable State and local regulations for energy conservation. They would also be subject to the City’s 2022 Building Electrification Ordinance, which requires most new residential development to be fully electric powered. In developing this ordinance, the City coordinated with energy providers, PG&E and Peninsula Clean Energy (PCE). PG&E acknowledged and is ready for full electrification of new and existing buildings by 2045. PG&E is advocating for all-electric policies like Half Moon Bay's, and for greater ability to decommission gas lines at the time of replacement and repair. It is noted that electric vehicle charging is more of a concern than buildings, but it’s being addressed and part of planning for the cumulative condition.

Lower-Income RHNA Analysis
HCD requires additional analysis of sites used to accommodate lower-income households in the 6th Cycle Housing Element. This additional review, of sites used in previous planning periods, appropriate density, and small and large sites, is focused on the six sites used to accommodate lower-income RHNA.
398
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 48 Table C-10: Sites Accommodating Lower-Income RHNA
Site # Address Units LCLUP /
General Plan
Zoning
District
Site Size
(AC)
Usable
Portion of
Site (AC)
1 880 Stone Pine* 50 PF U-R 20.66 4.50
2 498 Kelly Avenue 60 PF w/ WHO P-S 14.51 2.4
3 300 Block Church Street 52 PF w/ WHO P-S 1.90 1.55
5 101 Canada Cove Avenue 40 MHP MHP 4.12 4.12
11 940 Main Street** 41 R-H R-2 1.91 1.91
Source: City of Half Moon Bay
Notes: *Site #1: WHO will be added to PF land use designation and will be rezoned from U-R to P-S **Sites #6 and #11 will be upzoned from R-2 to R-3.

Sites Used in Previous Planning Periods
HCD requires an analysis of sites used to accommodate lower-income RHNA to determine if any were either non-vacant and included in the jurisdiction’s 5th cycle housing element, or vacant and included in the jurisdiction’s Cycle 4 and 5 Housing Elements (if not more). Of the five sites in the Site Inventory allocated for lower-income units, one site – Site # 11 – is predominately vacant and was included in Half Moon Bay’s Cycle 4 and 5 Housing Elements.

HCD requires that such sites be addressed to facilitate future development in that it has not yet occurred. This is typically done via a program in the Housing Element requiring rezoning within three years of the beginning of the planning period to allow residential use by right at 20 units/acre for housing developments in which at least 20% of the units are affordable to lowerincome households on Site #11.3 However, in this case, an affordable housing developer is in negotiations to purchase the site and has agreed with the property owner to modify the site in such a way so as to parcel off the existing historic home. This would result in a small site area, but the developable portion of the site would no longer be encumbered by the presence of the existing home. The parceled off portion of the site would also add value as a lot with a singlefamily home and room for additional units including ADUs and/or further subdivision for an additional lot. Provided that this approach moves forward, the City will not need to implement a zoning amendment.
3 HCD Division of Housing Policy Development “Housing Element Site Inventory Guidebook Government Code Section 65583.2” (HCD: June 10, 2020), p. 12. Available at https://www.hcd.ca.gov/communitydevelopment/housing-element/docs/sites_inventory_memo_final06102020.pdf 399
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 49 Sites that Allow Non-Residential Uses
HCD requires an analysis of the likelihood of development with a residential component on sites located in zoning districts that allow non-residential uses. Housing Opportunity Sites #4 and #7 are located in mixed-use zoning districts (Commercial-General/C-G and CommercialDowntown/C-D, respectively) where development could be 100% non-residential. Both sites are located within the Town Center near services and are identified for moderate-income units. From this perspective, these sites are similar to the three most recent developments of mixed-use buildings at 795 Main Street (complete, two units over commercial space), 415 Purissima Street (construction nearing completion, two units over commercial space), and 433 Main Street (construction underway, two buildings with two units over commercial space in one building and four units in single-use residential building). Furthermore, there have been no proposals for wholly non-residential development of such sites within the past ten years. In fact, two similarly sited properties that had been originally developed as homes and had converted to office uses, have been converted back to residential use in recent years, and two existing commercial buildings established residential use on the second floor where such space had formerly been used for office, storage, and other uses. Housing developers have expressed interest in site #4, and the owner of site #7 has discussed residential buildout options with City staff. Considering all of the above, and that on the San Mateo County Coastside, the residential market continues to be stronger than the commercial market, development of both of these sites would be expected to come forward as either mixed-use or single-use residential development.

Appropriate Density
Housing Elements are allowed to utilize “default” density standards that are deemed appropriate to accommodate housing for lower-income households. This provides a streamlined option for local governments to meet the density requirement.

The appropriate or default density for Half Moon Bay is 20 units/acre. Although the city is located on the western coastal edge of a metropolitan statistical area with a population of more than 2 million, Half Moon Bay has a population of 11,3084 – far lower than the 25,000-person limit laid out by HCD.5 The following zones have maximum densities that exceed the default density of 20 units/acre:
4 California Department of Finance Table E-1 (2022).
5 HCD Memo: “Default Density Standard Option – 2020 Census Update” (March 21, 2022), see Table A. Available at https://www.hcd.ca.gov/community-development/housing-element/housing-elementmemos/docs/defaultdensity2020censusupdate.pdf 400
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 50 Table C-11: Default Density
Zoning
District
Minimum
Density
Maximum
Density
R-3 15 29.04
C-D 15 29.04
C-VS 15 29.04
C-G 15 29.04
MHP N/A 21.78*
Source: City of Half Moon Bay Zoning Ordinance.

Note *=18.07.030(A) states that “The maximum permitted number of mobile home spaces shall be determined by dividing the net area of the site by two thousand square feet of site area per mobile home dwelling.” One acre divided by 2,000 square feet equals 21.78 dwelling units per acre.

Of the six sites Housing Opportunity Sites allocated for lower-income units, three are, or will be, zoned P-S; one is zoned MHP; and two will be rezoned R-3 following the Housing Element update process.

In addition to the zoning districts listed in Table C-10, the P-S zoning district can be appropriate to accommodate lower-income RHNA. This zoning district, for Public and Quasi-Public uses, includes many of Half Moon Bay’s publicly owned parcels. This zoning district, especially when combined with the WHO (which allows for densities of over 20 units/acre when overlayed on top of land use designations within the Town Center) can accommodate lower-income RHNA due to the unique nature of publicly owned land and the City’s interest in developing lower-income housing on some of these parcels at densities that are practical for affordable housing developers.

Small and Large Sites
HCD recommends that only parcels between 0.5 acres and 10 acres in size are used for a jurisdiction’s lower-income RHNA. Two of the five sites in the Site Inventory allocated for lowerincome units, Sites #1 and #2, are larger than 10 acres. However, both sites will have far less than the total site acreage dedicated to residential development (in this case lower-income housing development):

Site #1 – 880 Stone Pine Road: This is a City-owned site intended for lower-income housing.

According to environmental studies already completed for the site, approximately 4 acres of the parcel are available for housing development.

Site #2 – 498 Kelly Avenue: Owned by the Cabrillo Unified School District. Residential uses would only take up a portion of the parcel, which also is the site of Hatch Elementary School, Coastside Children’s Programs, Pilarcitos High School, La Costa Adult School, and offices of 401
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 51 the Cabrillo Unified School District. According to preliminary review of the site, approximately 4 acres of the parcel are available for housing development.

Parcel Consolidation
Parcel consolidation would be required to meet the realistic capacities for sites #8, #9, and #10, which are made up of multiple parcels. As already noted, each of these sites has one owner. All these owners will benefit from the forthcoming upzoning to the R-3 multi-family district which will allow them to develop more units. Lot mergers are straightforward matters that can be executed during or after the planning entitlement process. In most cases, the City includes a condition of approval for the coastal development permit that the merger be accomplished prior to issuance of the building permit. None of these sites have lower-income housing allocated to them.

Alternative Means of Meeting RHNA
Half Moon Bay also uses Accessory Dwelling Units, or ADUs, as part of its RHNA strategy. Half Moon Bay bases its ADU production on the "safe harbor" option provided by HCD,6 looking at ADU production from 2019-2021. For these years, there was an average of 14 ADUs permitted.

Based on this rate of production, 112 ADUs will be projected for completion over the eight-year planning period.

Table C-12: ADU Permits
Year
ADUs Receiving Building
Permits
2019 10
2020 10
2021 22
Average 14
Source: City of Half Moon Bay
Table C-13: Projected ADUs
Very Low Low Moderate Above
Moderate Total
Proportion 30% 30% 30% 10% 100%
ADUs 34 34 34 10 112
Source: City of Half Moon Bay
6 "Use the trends in ADU construction since January 2019 to estimate new production. This is a conservative option to only account for the effect of the new laws without local promotional efforts or incentives (safe harbor option)." In HCD Memo "Housing Element Site Inventory Guidebook Government Code Section 65583.2" (June 10, 2020). 402
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 52 Other Analyses
To conclude the Housing Sites Inventory section, there are two short additional analyses required by HCD noted here.

Non-Vacant Sites that Include Residential Units
Government Code Section 65583.2(g)(3) necessitates a program requiring the replacement of units affordable to the same or lower-income level as a condition of any development on a nonvacant site consistent with those requirements set forth in Density Bonus Law. There are no such units on non-vacant sites in the Site Inventory.

AB 1233: 5th Cycle Shortfall Review
Half Moon Bay had adequate sites available in its previous Housing Element cycle and is not required to accommodate any unaccommodated need. There is no rezoning necessary as per Government Code section 65584.09.

Quantified Objectives
Many programs and policies reduce barriers and create opportunities for a balanced community.

These goals are essential to meeting the City’s housing needs, but are more qualitative in general.

Half Moon Bay reasonably expects that a theoretical total of 542 units could be developed, rehabilitated, or conserved, as described by Table C-14. This includes Half Moon Bay’s 480-unit RHNA, 48 units rehabilitated per Program 21, and no units identified that require conservation or preservation (although ongoing monitoring will occur as per Program 2-2).

Measure D has a maximum capacity for an estimated 582 new units over the course of the planning period and will be adjusted as per Program 6-8 in the Housing Element. Adjusting for rehabilitation, a total of 542 units could be developed, rehabilitated, or conserved during Cycle 6 even within Measure D’s limits.
403
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 53 Table C-14 Quantified Objectives
Income Category
New
Construction
Objectives
Rehabilitation Conservation /
Preservation
Extremely Low 101 0 0
Very Low 80 16 0
Low 104 16 0
Moderate 52 16 0
Above Mod. 141 0 0
Sub-Totals 480 48 0
Total 542 units
Measure D Limited
Sub-Totals* 582 48 0
Measure D Limited Total 630 units
Source: City of Half Moon Bay
Notes: *See Technical Report Appendix B – Constraints, page B-38 for estimated Measure D capacity during Cycle 6.

404
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 54

AFFIRMATIVELY FURTHERING FAIR HOUSING (AFFH) SITES ANALYSIS Half Moon Bay is meeting its duty to affirmatively further fair housing with a focus on infill development, primarily in vacant sites and some underutilized sites.

This AFFH section discusses how the City’s identifying Housing Opportunity Site strategy, which allocates lower-income units in or near the Town Center, affirmatively furthers fair housing by supporting the residential development in the area of the city with the greatest access to amenities.7 The section will go over how the approach to the location of the Housing Opportunity Sites potentially improves and/or exacerbates conditions and describes how concentrating sites in or near the Town Center serves to alleviate the isolation of RHNA by income group. The section will then analyze local data and knowledge, as well as other relevant factors, to present the importance of leveraging the amenity-rich Town Center area to provide a suitable neighborhood context for lower-income housing.

Improved/Exacerbated Conditions
Half Moon Bay consists of nine Census block groups distributed through three Census tracts: six block groups and all the tracts cross City boundaries and include housing units outside of the city, complicating analysis.

Of the nine block groups that make up Half Moon Bay, four contain Housing Opportunity Sites:

Tract 6135.01:
 Block Group 2
Tract 6137:
 Block Group 1
 Block Group 4
 Block Group 5
Figure C-4 maps the Housing Opportunity Sites within Census tracts and block groups. Table C15 presents the Housing Opportunity Sites by block group in a table format. The table indicates that Housing Opportunity Site units will not drastically increase the number of units in any individual census block group.
7 This AFFH assessment is focused on the sites inventory. Technical Report - Appendix D: Affirmatively Furthering Fair Housing Assessment provides a comprehensive look at AFFH in Half Moon Bay. 405
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 55 Figure C-4: Sites by Census Tract and Block Group
Source: U.S Census Bureau, City of Half Moon Bay
406
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 56 Table C-15: RHNA by Census Block Group
Census Tract: 6135.01 6135.02 6137
Block Group: 6135.01-
BG1
6135.01-
BG2
6135.02-
BG1
6135.02-
BG2
6135.02-
BG3
6137-
BG1
6137-
BG3
6137-
BG4
6137-
BG5
Sites #12
#1, #3,
#4, #6,
#7, #8,
#9, #10,
#11
#2 #5
Total Units 0 44 0 0 0 244 0 60 40
Lower
Income 0 0 0 0 0 215 0 60 0
Moderate
Income 0 0 0 0 0 29 0 0 40
Above
Moderate
Income
0 44 0 0 0 0 0 0 0
Source: U.S. Census Bureau, City of Half Moon Bay
As presented in Table C-16, Census tract 6137 block group 1, sees by far the greatest number of Housing Opportunity Site units, representing an 18% increase from the existing 1,055 existing units. This block group’s boundaries substantially coincide with the City’s defined Town Center.

The Town Center boundary was set by the City and certified by the Coastal Commission as the best place in the city for infill development for numerous reasons. Thus, from the City’s perspective, this increase would fulfill long-range planning efforts to grow and improve Town Center neighborhoods.

Table C-16: Unit Increase by Census Block Group
Census Tract: 6135.01 6135.02 6137
Block Group 6135.01-
BG1
6135.01-
BG2
6135.02-
BG1
6135.02-
BG2
6135.02-
BG3
6137-
BG1
6137-
BG3
6137-
BG4
6137-
BG5
RHNA
Allocation 0 44 0 0 0 191 0 67 70
Units (2018) 703 664 486 642 610 1,055 474 811 939
Unit % Increase 0% 7% 0% 0% 0% 18% 0% 8% 7%
Source: U.S. Census Bureau, City of Half Moon Bay
407
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 57 Table C-17 below presents demographic information such as race/ethnicity, percentage of the population in poverty or disabled, existing rentals affordable to extremely/very low-income households, block group-wide household median-income, and proportion of owners to renters per Census block group. The data collection dates are given in parentheses.

Table C-17: Unit Increase and Existing Conditions
Census Tract: 6135.01 6135.02 6137
Block Group 6135.01-
BG1
6135.01-
BG2
6135.02-
BG1
6135.02-
BG2
6135.02-
BG3 6137-BG1 6137-BG3 6137-BG4 6137-BG5
Race/Ethnicity (2018)
% White 43% 57% 77% 74% 70% 53% 17% 67% 83%
% Hispanic 49% 33% 12% 16% 22% 39% 79% 23% 7%
% Asian and/or
Pacific Islander 5% 6% 5% 5% 3% 5% 2% 7% 7%
% Black 0% 0% 1% 0% 0% 0% 1% 1% 0%
% Multi-Racial,
Native
American, or
Other Race
3% 3% 4% 4% 5% 2% 1% 3% 3%
At-Risk Population (Tract-Level Data – 2019)
% Population
in Poverty 5% 5% 2% 2% 2% 9% 9% 9% 9%
% Population
Disabled 10% 10% 5% 5% 5% 11% 11% 11% 11%
Rentals Affordable to ELI/VLI Households (Year)
52 units 145 units 5 units
Household Median Income (2018)
$136,295 $130,246 $200,001 $152,127 $142,836 $124,775 $74,282 $122,165 $167,471 Tenure (2018)
% Owner 55% 83% 78% 78% 59% 51% 26% 85% 89%
% Renter 45% 17% 22% 22% 41% 49% 74% 15% 11%
Source: US Census 5-Year American Community Survey (2017-2021), City of Half Moon Bay As already noted, the largest number of units are allocated to Census tract 6137 block group 1, which is the most diverse Census block group in Half Moon Bay. Generally, the Housing Opportunity Sites strategy improves conditions by allocating more units to middle-income neighborhoods that already-existing diverse populations. No units are allocated to tract 6137 408
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 58 block group 3, which is the only majority-Hispanic block group and majority-renter block group in the city, as well as the one with the lowest median income.

Racially and Ethnically Concentrated Areas of Poverty and Affluence HCD requires jurisdictions to track Racially and Ethnically Concentrated Areas of Poverty and of Affluence (RECAP and RCAA, respectively). There are no areas designated as RECAP, where residents are largely persons of color and have lower incomes, in San Mateo County.

Figure C-5: Sites and RECAP
Source: Data from US Dept. of Housing and Urban Development (2009-2013). Methodology available at:
https://www.arcgis.com/home/item.html?id=9bc3297f5b434c8ba714a2603044dba0 409
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 59 In contrast, the entire city of Half Moon Bay is in an RCAA area, where the population is disproportionately white and affluent.

Figure C-6: Sites and RCAA
Source: Data from US Census American Community Survey (2015-2019). Methodology available at https://www.arcgis.com/home/item.html?id=4100330678564ad699d139b1c193ef14 410
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 60 Access to Opportunity (TCAC)
HCD and TCAC convened an independent group of organizations and research institutions under the umbrella of the California Fair Housing Task Force, which produces an annual set of Opportunity Area Maps. The maps identify areas within every region of the state “whose characteristics have been shown by research to support positive economic, educational, and health outcomes for low-income families – particularly long-term outcomes for children.”8 TCAC and HCD created these “Opportunity Maps” using reliable and publicly available data sources to derive 21 indicators to calculate Opportunity Index scores for Census tracts in each region of California.

The Opportunity Maps categorize Census tracts into the following five groups based on the Opportunity Index scores:
• Highest Resource
• High Resource
• Moderate Resource
• Low Resource
• High Segregation & Poverty
Before an area receives an Opportunity Index core, some Census tracts are filtered into the High Segregation & Poverty category. The filter identifies Census tracts where at least 30% of the population is below the federal poverty line and has a disproportionate share of households of color. After filtering out High Segregation and Poverty areas, the TCAC/HCD Opportunity Map allocates the 20% of tracts in each region with the highest relative Opportunity Index scores to the Highest Resource designation and the next 20% to the High Resource designation. The remaining non-filtered tracts are then evenly divided into Low Resource and Moderate Resource categories.

This section also analyzes the Education, Economy, and Environment TCAC scores. It also notes the Jobs and Transit analysis performed in the “Local Planning in Neighborhoods with RHNA Concentration” section of the chapter.

All Half Moon Bay falls within the “Moderate Resource” category (see Figure C-7). 8 California Fair Housing Task Force. December 2020. Methodology for the 2021 TCAC/HCD Opportunity Map.

Available at: https://www.treasurer.ca.gov/ctcac/opportunity/2021-hcd-methodology.pdf 411
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 61 Figure C-7: Sites by Opportunity Area
Source: California Fair Housing Task Force. December 2020. Methodology for the 2021 TCAC/HCD Opportunity Map. Available at: https://www.treasurer.ca.gov/ctcac/opportunity/2021-hcd-methodology.pdf, City of Half Moon Bay. 412
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 62 Education
The education score for the central portion of Half Moon Bay is slightly higher (0.52) than the northern and southern census tracts (0.40 and 0.47, respectively). These scores are somewhat lower than the higher education scores in other parts of San Mateo County.

Figure C-8: Sites by Education Domain Score
413
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 63 Economy
The economic score for the southern portion of Half Moon Bay is slightly higher (0.58) than the northern or central census tracts (0.49 and 0.45, respectively). These scores are also somewhat lower than the high economic scores across the mountains in the more populated parts of San Mateo, but on par with other Coastside communities.

Figure C-9: Sites by Economic Domain Score
414
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 64 Environment
The environment score in southern Half Moon Bay is 0.57, far higher than in the center (0.39) or north (0.22) of the city. Areas around the city tend to have lower environment scores, but the sparselypopulated census tracts far to the north or east have higher environment scores than in Half Moon Bay.

Figure C-10: Sites by Environmental Domain Score
415
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 65 Jobs and Transit
Further analysis of proximity to employment and transit is provided below, in the “Local Planning in Neighborhoods with RHNA Concentration” section. Figure C-9 shows transportation in Half Moon Bay and Figure C-10 depicts Jobs Proximity Index by census tract. Transit is concentrated along State Highway 1 (north-south along the coast) and State Highway 92 (going over the mountains to the more populated portions of the Bay Area. The Job Proximity Index shows a concentration of employment and connectivity in downtown Half Moon Bay, at the junction of State Highways 1 and 92.

Disproportionate Housing Needs
The majority of Housing Opportunity Site units are allocated to areas of the city that are at risk of becoming exclusive according to the University of California at Berkeley’s Urban Displacement Project.9
There is a chance that the large number of units allocated for lower-income households serves to mitigate this risk of exclusivity.

Table C-18: Displacement Risk by Census Block Group
Census
Tract: 6135.01 6135.02 6137
Category
6135.01-
BG1
6135.01-
BG2*
6135.02-
BG1
6135.02-
BG2
6135.02-
BG3 6137-BG1 6137-BG3 6137-BG4 6137-BG5
Sites #12
#1, #3,
#4, #6,
#7, #8,
#9, #10,
#11
#2 #5
Units 0 44 0 0 0 244 0 60 40
Units: Lower
Income 0 0 0 0 0 215 0 60 0
Units:

Moderate
Income
0 0 0 0 0 29 0 0 40
Units: Above
Moderate
Income
0 44 0 0 0 0 0 0 0
Displacement
Risk (2018)
Stable
Moderate/
Mixed
Income
Stable
Moderate/
Mixed
Income
Stable/
Advanced
Exclusive
Stable/
Advanced
Exclusive
Stable/
Advanced
Exclusive
At Risk of
Becoming
Exclusive
At Risk of
Becoming
Exclusive
At Risk of
Becoming
Exclusive
At Risk of
Becoming
Exclusive
Source: University of California Urban Displacement Project, https://abag.ca.gov/technical-assistance/sf-bay-area-mapgentrification-displacement 9 For more information, see: https://abag.ca.gov/technical-assistance/sf-bay-area-map-gentrification-displacement 416
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 66 Severe Overcrowding
Census data from 2020 identifies only 70 units out of 4,721 (1.5% of units) with severe overcrowding in Half Moon Bay. However, the Housing Needs Assessment (see Technical Report Appendix A) notes that 12% of very low-income households experience severe overcrowding and that communities of color are more likely to experience overcrowding similar to how they are more likely to experience poverty, financial instability, and housing insecurity.

Table C-19: Severe Overcrowding
OwnerOccupied
Units
RenterOccupied
Units
Total Units
Total Units 3,164 1,557 4,721
1 or fewer occupants per room 3,135 1,453 4,588

1.01 - 1.50 occupants per room 29 34 63

1.51 or more occupants per room 0 70 70
Source: US Census: American Communities Survey 5-Year Estimates (2016-2020) Table B25014: Tenure by Occupants Per Room.

In addition to the context presented in the next section about the Isolation of RHNA, it is important to consider gaps in existing data and how those gaps can be better understood within the context of the Housing Opportunity Sites strategy. Local outreach has identified issues with Census data around severe overcrowding, or units that are occupied by more than 1.5 persons per room. This disconnect between data and local knowledge informs this matter and helps the City better analyze how it relates to the Housing Opportunity Site strategy.

The low number of units identified in the Census as severely overcrowded puts it within the margin of error at the Census tract or Census block group level, making it difficult to statistically determine where these severely overcrowded units are located within the city. Programs 3-3 and 3-5 address overcrowding by providing incentives and diverse housing opportunities to support large and multigenerational households.

Isolation of RHNA
Half Moon Bay’s Housing Opportunity Site strategy locates units accommodating lower-income RHNA in or near the city’s Downtown. This is an intentional choice that puts lower-income households in the most amenity-rich neighborhoods of Half Moon Bay’s Town Center, where households will be better connected to transit, employment opportunities, and social connections. This ensures that households are not isolated in areas where they would be cardependent and/or far from services.

This section presents the local planning context for Downtown neighborhoods with RHNA concentration by highlighting amenities and laying out the relationship between transportation and employment.
417
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 67 Local Planning in Neighborhoods with RHNA Concentration Concentrating future residential development in Downtown Half Moon Bay and the greater Town Center area, particularly lower-income units, is supported by the City’s ongoing planning work.

Such efforts include recent adoptions of the Parks Master Plan (2019), Bicycle and Pedestrian Master Plan (2019), and Mixed-Use Districts and Parking Standards Zoning Ordinance (2020). The Town Center, as defined in the LCLUP, is in the census tract with the highest Jobs Proximity Index in the city. It is also the location of Half Moon Bay’s only health clinic, its community center, all its grocery stores and produce markets selling fresh produce, and the highest concentration of SamTrans transit stops and public parks. In addition, every public school in Half Moon Bay is located within, or immediately adjacent to, the Town Center.

Half Moon Bay’s LCLUP and Circulation Element include policies that support multi-modal improvements throughout the Town Center. Implementation plans, such as the Bicycle and Pedestrian Master Plan also focus on Downtown as a “key theme,” with recommendations and implementation measures that identify needed improvements, including those that would better accommodate bicycles and pedestrians.10 At the time of the Housing Element update, the City had two Capital Improvement Projects underway within the heart of Downtown Half Moon Bay aimed at revitalization and pedestrian safety to enhance Downtown as a high quality neighborhood environment primed for residential infill development. These include a streetscape project and coordinated plans for improved ADA, pedestrian, and bicycle circulation.

These revitalization efforts support a live/work downtown that can be a vibrant neighborhood for the households who be residing in units allocated in or near this area. Figure C-8 maps amenities in or near Downtown and the Housing Opportunity Sites. 10 City of Half Moon Bay Bicycle and Pedestrian Master Plan (September 2019). Available at https://www.half-moonbay.ca.us/DocumentCenter/View/2243/Bicycle-and-Pedestrian-Master-Plan-Final?bidId= 418
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 68 Figure C-8: Amenities in or near Downtown
Source: City of Half Moon Bay
419
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 69 Transportation and Employment
Half Moon Bay’s employed residents predominately out-commute to jobs “over the hill” in San Mateo and Santa Clara Counties, San Francisco, and the East Bay. Less than 20% of workers who reside in Half Moon Bay also work in the city, making transportation to employment outside the city key for working Half Moon Bay residents to get to their workplaces. The majority of Half Moon Bay residents, in combination with many Coastside residents, drive to work, often in singleoccupant vehicles.

Half Moon Bay has limited transit service.11 Yet, transit access is key for lower-income households because it allows for social connectivity to areas throughout the Bay Area region and access to higher-paying jobs in other areas, most being outside the city. It is foreseeable that it will be justifiable from a public investment perspective that transit would expand in areas where potential ridership is increasing. Therefore, it is notable that every Housing Opportunity Site allocated for affordable units is within a quarter mile of a transit stop. This is due to the high concentration of SamTrans bus stops in the Town Center, at the confluence of HWY 1 and 92 as presented in Figure C-9. Furthermore, SamTrans initiated microtransit service within the City limits in June 2023 having determined that microtransit is both more cost-effective and responsive to local needs than bus service for this somewhat isolated Coastside community.

Thus, all of the Housing Opportunity Sites also now have access to affordable microtransit service for routine trips within the city limits.
11 California Public Resource Code, Division 13 Environmental Quality Chapter 2.5 21064.3 at https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=21064.3.&lawCode=PRC 420
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 70 Figure C-9: Housing Opportunity Sites and Transit
Source: Samtrans, City of Half Moon Bay
421
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 71 Jobs Proximity Index: Half Moon Bay’s downtown, where the Town Center is located, is the area of the city with the highest Jobs Proximity Index. This rating quantifies the accessibility of a given residential neighborhood as a function of its distance to all job locations within a metropolitan area, with larger employment centers weighted more heavily.12 The higher the index value, the better the access to employment opportunities for residents in a neighborhood.

Table C-20: Jobs Proximity Index by Census Block Group
Census Tract: 6135.01 6135.02 6137
Category 6135.01-
BG1
6135.01-
BG2
6135.02-
BG1
6135.02-
BG2
6135.02-
BG3
6137-
BG1
6137-
BG3
6137-
BG4
6137-
BG5
Sites #12
#1, #3,
#4, #6,
#7, #8,
#9, #10,
#11
#2 #5
Units 0 44 0 0 0 244 0 60 40
Units: Lower
Income 0 0 0 0 0 215 0 60 0
Units: Moderate
Income 0 0 0 0 0 29 0 0 70
Units: Above
Moderate
Income
0 44 0 0 0 0 0 0 0
Jobs Proximity
Index (2017) 52 61 58 57 56 75 54 48 50
Source: California Fair Housing Task Force. December 2020. Methodology for the 2021 TCAC/HCD Opportunity Map. Available at:
https://www.treasurer.ca.gov/ctcac/opportunity/2021-hcd-methodology.pdf, City of Half Moon Bay This high score in Tract 6137 Block Group 1 is not only due to the high concentration of jobs within the Town Center, but also because it is relatively easy to get to employment centers north, south, and east of Half Moon Bay via HWYs 1 and 92. Housing Opportunity Sites designated for lower-income households in the Cycle 6 Housing Element RHNA have relatively high access to employment, both within the city and in nearby employment centers. 12 More information on the Jobs Proximity Index methodology is available at https://www.arcgis.com/home/item.html?id=c0de1bf7b05c4e128ef9ed3644c5f6e9.

The most recent data set ranges from 2014-2017.
422
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 72 Figure C-10: Sites and Job Proximity Index
Source: City of Half Moon Bay
423
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 73 The majority of workers in Half Moon Bay work outside of the city, where wages are generally much higher than they are within the city. Access to transit is a key need for lower-income households in Half Moon Bay to access higher-wage employment that exists in greater abundance outside the city. All Housing Opportunity Sites allocated to lower-income RHNA are within a 15-minute walk of public transit.

Figure C-11: Wage Distribution by Area of Employment (All Private Jobs) Sources: U.S. Census Bureau, OnTheMap Application and LEHD Origin-Destination Employment Statistics (Beginning of Quarter Employment, 2nd Quarter of 2002-2019) (All Private Jobs) Housing Opportunity Site Strategy and Existing Local Amenities In addition to transit and employment access, numerous additional amenities support the Housing Opportunities Sites which are near public parks, public schools, grocery stores selling fresh produce, and other “shopping areas” that allow commercial and retail uses.

Public Parks: Public parks, particularly parks with playgrounds or that host children’s activities, are a crucial node of social connectivity and public health for a city. This is especially true for lower-income households who may not have access to private camps, pools, or play areas. The City’s parkland standard is 5 acres/1,000 residents, and new development supports creation of park space through dedications and/or in lieu fees to maintain this standard. Moreover, Half Moon Bay is unique in that much of its public park space also serves as public beach. While the beaches themselves are not particularly close to Housing Opportunity Sites, they complement the city’s public parks and provide public recreation opportunities for Half Moon Bay residents.

All the sites allocated for lower-income units are near public parks, as are some moderate and above-moderate sites.
32%
13% 16% 14%
30%
21% 23%
20%
38%
67%
61%
67%
0%
10%
20%
30%
40%
50%
60%
70%
Half Moon Bay San Mateo County San Francisco MSA San Jose MSA Wage Distribution by Area of Employment
$1,250 or less/month $1,251 to $3,333/mo More than $3,333/mo 424
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 74 Figure C-12: Sites and Parks
Source: City of Half Moon Bay
425
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 75 Public Schools: Half Moon Bay is served by the Cabrillo Unified School District (CUSD), which includes four schools within the city:
• Alvin S. Hatch Elementary School
• Manuel F. Cunha Intermediate School
• Half Moon Bay High School
• Pilarcitos High School and Alternative Education
There are three other elementary schools in the District outside of the city, Farallone View (Montara), Kings Mountain (Kings Mountain), and El Granada (El Granada).

Manuel F. Cunha Intermediate School is in the heart of Downtown Half Moon Bay. Half Moon Bay High School is just north of downtown. Alvin S. Hatch Elementary School and Pilarcitos High School share a campus across HWY 1 from downtown. A 4-acre portion of the Hatch school property is allocated as a Housing Opportunity Site for lower-income RHNA in the Site Inventory (Site #2). This site is readily reachable from downtown for all transportation modes, including pedestrians and bicycles via a signalized intersection of HWY 1 at Kelly Avenue.

Cabrillo Unified has partnered with SamTrans to assist students with transportation. Routes 18 and 117 serve district schools.13
Walkable access to Half Moon Bay’s public schools allows for lower-income households to have easier commutes and improves social connectivity by easing student access to schools and family relationships with the schools. While only three Housing Opportunity Sites (two lower-income, one above moderate-income) are within a quarter mile of a public school, 10 of the 12 sites are on or near school bus routes that connect to Cabrillo School District schools. 13 Cabrillo Unified School District – Transportation, Available at https://www.cabrillo.k12.ca.us/our_departments/transportation 426
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 76 Figure C-13: Sites and Schools
Source: City of Half Moon Bay
427
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 77 Groceries: All of Half Moon Bay’s grocery stores selling fresh produce are in the downtown area.

Half Moon Bay is located amidst a highly valued coastal agricultural region where produce stands, such as Tom & Pete’s in the downtown and the Andreotti Family Farm produce market just west on Kelly Avenue expand access to fresh produce. The popular Half Moon Bay Farmer’s Market, open Saturdays, April – December, and is also located downtown.

Figure C-14: Sites and Groceries
Source: City of Half Moon Bay
428
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 78 The concentration of Housing Opportunity Sites allocated to Lower-Income RHNA allows lowerincome households to purchase food without requiring a trip in a personal automobile. The majority of affordable units in the Housing Opportunity Sites strategy are within a quarter mile of a grocery store. Some sites are also near a produce market.

Shopping Areas: Shopping Areas – defined as a quarter mile from parcels where commercial and retail uses are permitted – encompass the downtown area. These are units with either a Commercial – General or Commercial – Visitor Serving land use designation. Every parcel allocated for affordable units is within a Shopping Area This proximity to commercial and retail uses, including the shopping centers concentrated at the intersection of HWYs 1 and 92, allows households in affordable units to make purchases without requiring use of a car, which saves these households dramatically in transportation costs.

Figure C-15: Sites and Shopping Areas
Source: City of Half Moon Bay
429
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 79 AFFH Site Assessment Conclusions
Half Moon Bay is a rural jurisdiction that is a relatively short commute to the job centers across the Santa Cruz Mountains in San Francisco, San Mateo County, and Santa Cruz County. This makes the city attractive because it is near jobs offering relatively high wages even as it is still relatively affordable compared to cities on the other side of the mountains. However, these transmountain commuters impact affordability for people working in Half Moon Bay’s lower-wage service jobs as well as agricultural jobs. Furthermore, housing costs began to increase steeply at the beginning of the COVID pandemic as people sought respite from urban areas and were able to work from home.

The Housing Opportunity Sites strategy concentrates housing, particularly lower-income housing, in Half Moon Bay’s downtown core. This locates lower-income residents near amenities, transit, jobs, parks, public schools, and grocery stores, as well as Half Moon Bay’s only medical clinic, library, and community center. This concentration strategy keeps lower-income households socially connected and limits transportation costs, which would not be possible if the lowerincome units were in areas that may have higher opportunity according to TCAC methodology but are otherwise extremely rural in nature.

The strategy also remedies segregation by concentrating lower-income, moderate-income, and above moderate-income units in Half Moon Bay’s most diverse Census block groups. By bringing more housing units at all affordability levels into Half Moon Bay’s downtown, the strategy improves conditions and increases integration by bringing a greater proportion of the city’s population into contact with one another near amenities. A more scattered sites approach would increase transportation costs and decrease social contact while not affecting shared use of city amenities, noting that Half Moon Bay has only one school district and all its groceries are located downtown.

The Housing Opportunity Sites strategy is complemented by the Housing Element Update’s Pipeline Project and ADU allocations, which will see sites distributed more widely throughout the city. In addition, the City has policies for farmworker housing that establish such housing as both a Coastal Act priority land use as well as a City priority use. The LCLUP WHO designation now allows this housing on properties that had previously allowed a very limited number of units, or prohibited such units. The overall strategy is meant to bring forth farmworker housing units throughout the City’s small farms and horticultural use sites. Employees can live where they work in the more traditional approach to this; however, sites can be established for farmworkers who work anywhere in the Coastside agricultural industry. On top of that, traditional multi-family affordable housing is also being planned within the Town Center core for older farmworkers and farmworker families. This housing would not have a relationship to any particular agricultural operation, providing freedom and support for these employees to enjoy both safe, quality housing and employment options. This multifaceted approach concentrates lower-income housing in and near the downtown, where there are many amenities for lower-income households, while distributing housing throughout the city and particularly near farms through other strategies contained in the Housing Element.
430
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 80

FINANCIAL HOUSING RESOURCES
The following section provides an overview of financial resources available for preserving and creating housing in Half Moon Bay and the surrounding Coastside. Many of the resources identified in this section are vital to financing programs that directly benefit current and new residents. Veterans, seniors, families, people with disabilities, farmworkers, and homeless populations have been aided by these programs.

Half Moon Bay Affordable Housing Fund
The City’s Affordable Housing Fund (AHF) is the sole source of local funding that the City utilizes directly towards supportive housing programs and affordable housing development. Up to this point, it has been solely funded by the collection of in-lieu fees from the Below Market Rate Housing program and the City’s General Fund. The projected balance at the end of the 2022/2023 fiscal year is $2.11 million. In addition to fund utilization, the City may choose to combine monetary support through the use of the AHF and City-owned land. Although City-owned property suitable for housing is very limited, the City is supporting development of affordable senior farmworker housing at 555 Kelly Avenue (see Table C-4, Pipeline Project site AJ) by leveraging City-owned land and AHF contributions. During the COVID-19 pandemic, the City allocated AHF funds to support emergency rental assistance programs and ensure housing stability for nearly 100 households.

City support represents a portion of a much larger funding requirement for developing, maintaining, and operating affordable housing; especially for extremely low- and very lowincome units. Most affordable housing development cannot be built without financing and other subsidies to lower land, design, and construction costs. Development incentives to reduce overall project costs are also important and can be significant. Funding sources include the HUD, HCD, tax credits, and other loans and grants.

Urban County and HOME Consortium
The City of Half Moon Bay is part of the County of San Mateo’s Urban County and HOME Consortium, which gives the City and city residents access to housing rehabilitation, new housing construction, and homebuyer assistance programs from federally supported funding. These HUD programs include services funded through the Community Development Block Grant (CDBG) and HOME Investments Partnership Program (HOME), which are administered by San Mateo County on behalf of the Urban County and HOME Consortium.

CDBG: Through the CDBG program, HUD provides funds to local governments for a wide range of community development activities. These funds can be used for the acquisition of land for affordable housing units, rehabilitation through a nonprofit organization for housing, development of infrastructure and facilities, and public service activities. Projects in Half Moon Bay would apply to the County of San Mateo to access these types of funds. 431
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 81 HOME: These funds can be used to assist tenants or homeowners through acquisition, construction, reconstruction, or rehabilitation of affordable housing. A federal priority for use of these funds is preservation of the at-risk housing stock. Similarly, access to HOME funds is coordinated by the County of San Mateo.

Housing Choice Voucher Program: The Housing Authority of the County of San Mateo (HACSM) administers the HUD Section 8 Housing Choice Voucher Program for Half Moon Bay residents.

The program provides rental subsidies to low-income families who spend more than 30 percent of their gross income on housing costs. The program pays the difference between 30 percent of the recipients’ monthly income and the federally approved payment standard. The voucher allows a tenant to choose housing that may cost above the payment standard but the tenant must pay the extra cost. As of March 2023, a total of 203 vouchers were associated with addresses in Half Moon Bay. San Mateo County has a total of 5,208 vouchers in use for this same period.

Moving to Work Program: HUD introduced Moving To Work (MTW) in 1996 as a demonstration program for 24 housing authorities. HUD grants MTW agencies exceptions to federal regulations to research whether local innovation can provide incentives to families to become economically self-sufficient, reduce program costs and achieve greater cost-effectiveness, or increase housing choices for low-income families.

Under the original agreement with HUD, HACSM was authorized to design and carry out a demonstration program for 300 families receiving tenant-based assistance. The demonstration exempted HACSM from most of the regulatory requirements that would otherwise apply to these families. In April 2008, HUD signed a 10-year MTW Agreement with HACSM to expand its MTW program. As a result of Congress passing the Consolidated Appropriations Act of 2016, HACSM’s MTW Agreement was modified and extended to the end of its Fiscal Year 2028.

Under the MTW Agreement, HACSM is given the authorization to develop policies that are outside the limitations of certain HUD regulations and provisions of the Housing Act of 1937. This expansion applies to the original MTW demonstration program of 300 families in addition to the other Housing Choice Voucher programs administered by HACSM. The additional flexibility offered by MTW allows HACSM to more successfully achieve its mission and program goals, as well as enhance its ability to serve the needs of low-income households and communities in San Mateo County. The Half Moon Village Redevelopment project in Half Moon Bay, completed in 2014, received support through this program.

Housing Rehabilitation Program: The Consortium provides a housing rehabilitation program operated by the San Mateo County Department of Housing (DOH) and HASCM. These loans are available to lower-income Half Moon Bay households and cover moderate or substantial rehabilitation to single-family residences and rental properties that benefit very low- and lowincome households. HACSM funds and collaborates with non-profit organizations to provide 432
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 82 these services for minor home repairs. In Half Moon Bay, Senior Coastsiders is the designated provider for Half Moon Bay and unincorporated Coastside neighborhood residents.

State Housing Resources
Low Income Housing Tax Credits (LIHTC): Created by the 1986 Tax Reform Act, the LIHTC program has been used in combination with City and other resources to encourage construction and rehabilitation of rental housing for lower-income households. The program allows investors an annual tax credit over 10 years, provided that the housing meets the following minimum lowincome occupancy requirements: 20% of the units must be affordable to households at 50% of AMI or 40% of the units must be affordable to those at 60% of AMI. The total credit over 10 years has a present value equal to 70% of the qualified construction and rehabilitation expenditure.

The tax credit is typically sold to large investors at a syndication value.

State Grants & Funding: There are a large number of programs HCD provides and/or facilitates.

HCD creates rental and homeownership opportunities for communities throughout California.

Over the last three decades, HCD has awarded more than $3 billion in funding for development of affordable housing and associated infrastructure. The majority of these funding sources require long-term monitoring that allows HCD, in partnership with local jurisdictions such as Half Moon Bay and the County of San Mateo, to ensure developments continue to provide safe and affordable homes, and that the homes remain well-maintained and reliable financial standing.

Housing resources available to many jurisdictions throughout the State include:
• Affordable Housing and Sustainable Communities (AHSC) • Joe Serna, Jr. Farmworker Housing Grant Program (FWHG) • CalHFA Single and Multi-Family Program
• CalHome Program
• Homekey
• Housing-Related Parks Grant
• Infill Infrastructure Grant (IIG)
• Local Housing Trust Fund (LHTF)
• Multifamily Housing Program (MHP)
• No Place Like Home
• Permanent Local Housing Allocation (PLHA)
Local Housing Resources
Housing Endowment and Regional Trust of San Mateo County (HEART): HEART was formed in 2003 as a public/private partnership among the San Mateo cities and county, and the business, nonprofit, education, and labor communities. HEART raises funds from public and private sources to meet critical housing needs in San Mateo County. For example, HEART operates a First Time Homebuyer Program that assists buyers with purchasing a home with a 5% downpayment without the need for Private Mortgage Insurance.
433
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 83 Human Investment Project (HIP) Housing: HIP Housing is a nonprofit organization whose mission is to enable people with special needs to live independent, self-sufficient lives in decent, safe, low-cost homes. HIP offers a Home Sharing Program, which facilitates living arrangements in which two or more unrelated people share a home or apartment. In a related service, HIP provides a home equity conversion program, which allows senior homeowners to convert the equity in their homes into monthly income, without giving up their property. The Self Sufficiency Program (SSP) provides housing assistance and support services to low-income parents or emancipated foster youth who are in school to increase their earning power and become financially self-sufficient within 1-5 years. Participants receive subsidized rent while they complete an education or job training program and find employment in their field.

San Mateo County Continuum of Care Strategic Plan on Homelessness: The San Mateo County Continuum of Care is committed to preventing homelessness and ensuring anyone who is experiencing homelessness is supported with safe shelter and a pathway to housing. The July 2022 - June 2025 strategic plan builds upon and updates the 2016 plan to set forth a vision and roadmap for the community’s response to homelessness over the next three years. This plan also satisfies requirements of the State of California to develop a Homelessness Action Plan, a prerequisite for requesting funding under the State’s Homelessness, Housing Assistance and Prevention (HHAP) program.

There are eight Core Service Agencies in San Mateo County that work in close collaboration with the County’s Human Services Agency to provide individuals and families with basic emergency and support services to stabilize their living situations. Core Service Agencies provide clients with crisis intervention and referrals based on an evaluation of their needs and qualifications for assistance. Core Service Agencies provide safety net services to San Mateo County residents in need of food, emergency housing assistance, emergency utility assistance, shelter, and other basic needs. Coastside HOPE is the Core Service Agency that provides services in Half Moon Bay.

Coastside HOPE: Previously known as the Coastside Opportunity Center, Coastside HOPE is chartered by San Mateo County to be a core human services agency. It is headquartered in El Granada and provides assistance to homeless individuals and families in the form of food pantry services, rental assistance, motel vouchers, and referrals for homeless resources in Half Moon Bay and the surrounding Coastside. During the fiscal year 2021-2022, Coastside HOPE provided safety net services to 3,788 people in 1,467 households.

San Mateo County Affordable Housing Fund: The San Mateo County Affordable Housing Fund was established in 2013 and is comprised of Measure K funds and other local and State housing funding sources. Together with its Preservation sub-fund, the County has allocated over $120 million to assist 2,761 units in San Mateo County—supporting development of 2,403 new affordable rental and homeownership units, and preservation as affordable housing of 358 multifamily rental units. 434
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 84 San Mateo County: The City of Half Moon Bay relies on close collaboration with the County of San Mateo to provide services and housing opportunities to the community. The San Mateo County DOH administers the HUD Section 8 Housing Choice Voucher Program for Half Moon Bay residents. In addition, the San Mateo County DOH administers the County’s Affordable Housing Fund and other housing programs and the County’s Human Services Agency coordinates homelessness response for the County and the HSA’s Center on Homelessness serves as San Mateo County's Continuum of Care. The City also works closely with the County Executive’s Office to collectively leverage State and federal financing opportunities that support the development of affordable housing. The City of Half Moon Bay is appreciative of the County’s commitment to better the lives of Coastside residents.

Partnerships
Half Moon Bay relies on strong collaboration with various organizations to provide affordable housing and related support services. Many of these agencies rely on various federal, State, and local funding sources to maintain operations. If these service organizations were to lose funding support from the sources identified above in this section, City resources would be impacted, and/or the level of services and support for residents would most certainly be affected.

Some of these local partners include:
• Abode Services (housing services provider)
• Abundant Grace Coastside Worker (homeless workforce development and services) • Ayudando Latinos A Soñar (mental health services, case management, immigration, education, farmworker needs, and advocacy, and social justice advocacy initiatives) • Coastside Hope (core service agency, supports rental assistance and safety net services) • Dignity on Wheels (homeless services such as mobile showers and laundry) • HIP Housing (supports home sharing, self-sufficiency, and property development/housing rehabilitation)
• Habitat for Humanity Greater San Francisco (builds and rehabilitates homes for affordable ownership)
• Housing Choices (developmental disabilities service provider) • LifeMoves (homeless services provider)
• Mercy Housing (designs, develops, and manages affordable housing) • Mental Health Association of San Mateo County (housing and services provider) • MidPen Housing (designs, develops, and manages affordable housing) • Project Sentinel (landlord/tenant rights education, housing resources) • Peninsula Conflict Resolution (conflict mediation services, landlord/tenant dispute resolution)
• Rebuilding Together Peninsula (home renovation and repair for low-income households) • Samaritan House (lead core service agency for San Mateo County) • San Mateo Legal Aid Society (no-cost legal advice, housing rights) • Second Harvest Food Distribution (monthly grocery distribution) • Senior Coastsiders (senior support services and home repair) • St. Vincent de Paul Society (homeless services, food pantry, and rental assistance) 435
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 85

OTHER RESOURCES
Incentives for Affordable Housing Development
In addition to the affordable housing resources listed above, the City offers incentives to promote development of housing affordable to very low- and low-income households. The City assists housing developers by providing support in the following areas:
• Exemptions from growth allocation requirements for density bonus units • Density bonus and related incentives
• Waiver or reduction of development requirements for affordable units (e.g., parking standards)
• Reduced development standards for substandard and severely substandard lots These provisions are discussed in more detail in the Constraints Technical Report, Appendix B.

Resilience in Residential Development
Environmental Hazard Protection: As acknowledged in other Technical Reports of this Housing Element, Half Moon Bay and Coastside communities are vulnerable to numerous environmental hazards, including adjacency of high fire risk areas; flooding from numerous water courses, rising sea level, tsunamis, and dam inundation; seismic and geological conditions including liquefaction, landslide; as well as on-going coastal and watercourse erosion.

Being highly relevant to the safety and condition of both existing and new development, the City has been working to address, in particular through the recently certified LCLUP, which includes a substantial assessment of hazards and how to manage and/or reduce these threats to the extent feasible. Other policy and implementation planning include the City’s Safety Element update, which is coming forward and trailing the Housing Element, regular updates to the Local Hazard Mitigation Plan is updated as required, and work on evacuation planning. Half Moon Bay is fortunate to be further supported by devoted community volunteers, including a Community Emergency Response Team (CERT) group and an active ham radio community.

Policy and implementation efforts that protect Half Moon Bay’s homes of existing and future community members are critical housing resources in coastal communities, especially with exacerbation of nearly all these environmental hazards stemming from climate change.

Sustainable Development:

Half Moon Bay’s sustainability focus supports better housing development that will be less expensive to operate and maintain over time and be climate friendly. The key to achieving such an outcome is low and appropriate energy use, effective water conservation, and reduced vehicle miles traveled (VMT). Programs 5-1 through 5-3 support this goal. 436
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix C – Housing Resources Page | C - 86 Energy: Half Moon Bay’s 2022 Building Electrification Ordinance shifts future development to all-electric powered buildings which are constructed to be highly energy efficient per Title 24.

Water: Efficient water use is imposed through State and local water conservation requirements.

Development design incorporates low-water demand systems and landscaping that will last for many years and cost much less to maintain due to lower water rates.

VMT: Most of the Housing Opportunity Sites are located in the Town Center. Numerous benefits of this location were presented earlier in this report. One benefit is that many amenities are within walking distance. This part of town also has the highest concentration of bus stops in Half Moon Bay. The Town Center is the City’s focus for transportation support and is most likely to see future amenities such as micro-transit as a resource for the various Downtown neighborhoods within this area.

Other sustainability measures include provision of photovoltaic and electric vehicle charging systems which do not reduce VMT, but certainly can reduce greenhouse gas emissions associated with both residential energy uses, as well as driving. The City is taking a holistic approach to sustainable development and is committed to supporting associated infrastructure needs, making for another important housing resource.
437
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 1 Technical Report Appendix D:

Affirmatively Further Fair Housing Assessment
WHAT IS AFFH?
The State of California’s 2018 Assembly Bill (AB 686) requires that all public agencies in the state affirmatively further fair housing (AFFH) beginning January 1, 2019. Public agencies receiving funding from the U.S. Department of Housing and Urban Development (HUD) are also required to demonstrate their commitment to AFFH. The federal obligation stems from the fair housing component of the federal Civil Rights Act mandating federal fund recipients to take “meaningful actions” to address segregation and related barriers to fair housing choice.

AB 686 requires all public agencies to “administer programs and activities relating to housing and community development in a manner that affirmatively furthers fair housing, and take no action inconsistent with this obligation”1
AB 686 also makes changes to Housing Element Law to incorporate requirements for AFFH as part of the housing element and general plan to include an analysis of fair housing outreach and capacity, integration and segregation, access to opportunity, disparate housing needs, and current fair housing practices.

Affirmatively Furthering Fair Housing
“Affirmatively furthering fair housing” means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. The duty to affirmatively further fair housing extends to all of a public agency’s activities and programs relating to housing and community development. (Gov. Code, § 8899.50, subd. (a)(1).)”
Source: California Department of Housing and Community Development Guidance, 2021, page 14. 1 California Department of Housing and Community Development Guidance, 2021, page 9. 438
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 2 History of segregation in the region. The United
States’ oldest cities have a history of mandating
segregated living patterns—and Northern California
cities are no exception. ABAG, in its recent Fair
Housing Equity Assessment, attributes segregation in
the Bay Area to historically discriminatory
practices—highlighting redlining and discriminatory
mortgage approvals—as well as “structural
inequities” in society and “self segregation” (i.e.,
preferences to live near similar people).

Researcher Richard Rothstein’s 2017 book The Color
of Law: A Forgotten History of How Our Government
Segregated America chronicles how the public sector
contributed to the segregation that exists today.

Rothstein highlights several significant
developments in the Bay Area region that played a
large role in where the region’s non-White residents
settled.

Pre-civil rights San Mateo County faced resistance to
racial integration, yet it was reportedly less direct than in some Northern California communities, taking the form of “blockbusting” and “steering” or intervention by public officials. These local discriminatory practices were exacerbated by actions of the Federal Housing Administration which excluded low-income neighborhoods, where the majority of people of color lived, from its mortgage loan program.

According to the San Mateo County Historical Association. San Mateo County’s early African Americans worked in a variety of industries, from logging to agriculture, to restaurants and entertainment. Expansion of jobs, particularly related to shipbuilding during and after World War II attracted many new residents into the Peninsula, including the first sizable migration of African Americans. Enforcement of racial covenants after the war forced the migration of the county’s African Americans into neighborhoods where they were allowed to occupy housing—housing segregated into less desirable areas, next to highways, and concentrated in public housing and urban renewal developments.

The private sector contributed to segregation through activities that discouraged (blockbusting) or prohibited (restrictive covenants) integrated neighborhoods. In the City of San Mateo, builders of the Hillsdale neighborhood in the mid-1900s recorded deeds that specified that only “members of the Caucasian or White race shall be permitted” to occupy sold homes—the exception being “domestics in the employ[ment] on the premises.”2 This 2 https://www.nytimes.com/2020/08/14/opinion/sunday/blm-residential-segregation.html This history of segregation in
the region is important not
only to understand how
residential settlement
patterns came about—but,
more importantly, to explain
differences in housing
opportunity among residents
today. In sum, not all
residents had the ability to
build housing wealth or
achieve economic
opportunity. This historically
unequal playing field in part
determines why residents
have different housing needs
today.
439
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 3 developer went on to develop many race-restricted neighborhoods in the Bay Area, became president of the National Association of Home Builders (NAHB), became national president of the Urban Land Institute (ULI), and was inducted into California’s Homebuilding Foundation Hall of Fame.

The segregatory effect of blockbusting activities is well-documented in East Palo Alto. In 1954, after a White family in East Palo Alto sold their home to an African American family, the then-president of the California Real Estate Association set up an office in East Palo Alto to scare White families into selling their homes (“for fear of declining property values”) to agents and speculators. These agents then sold these homes at over-inflated prices to African American buyers, some of whom had trouble making their payments. Within six years, East Palo Alto—initially established with “whites only” neighborhoods—became 82% African American. The FHA prevented re-integration by refusing to insure mortgages held by White buyers residing in East Palo Alto.

Throughout the county, neighborhood associations and city leaders attempted to thwart integration of communities. Although some neighborhood residents supported integration, most did not, and it was not unusual for neighborhood associations to require acceptance of all new buyers. Builders with intentions to develop for all types of buyers (regardless of race) found that their development sites were rezoned by planning councils, required very large minimum lot sizes, and\or were denied public infrastructure to support their developments or charged prohibitively high amounts for infrastructure.

In addition to historical discriminatory practices that embedded segregation into living patterns throughout the Bay Area, it’s also necessary to recognize the historical impacts of colonization and genocide on Indigenous populations and how the effects of those atrocities are still being felt today. The original inhabitants of present-day San Mateo County are the Ramaytush Ohlone, who have “…lived on the San Francisco Peninsula for thousands of years and continue to live here as respectful stewards of the land.”3 However, “[d]ue to the devastating policies and practices of a succession of explorers, missionaries, settlers, and various levels of government over the centuries since European expansion, the Ramaytush Ohlone lost the vast majority of their population as well as their land.”4 The lasting influence of these policies and practices has contributed directly to the disparate housing and economic outcomes collectively experienced by Native populations today.5 The timeline of major federal Acts and court decisions related to fair housing choice and zoning and land use appears on the following page.

As shown in the timeline, exclusive zoning practices were common in the early 1900s. Courts struck down only the most discriminatory, and allowed those that would be considered 3 https://www.smcoe.org/for-communities/indigenous-people-of-san-mateo-county.html 4 https://www.smcoe.org/for-communities/indigenous-people-of-san-mateo-county.html 5 https://www.americanprogress.org/article/systemic-inequality-displacement-exclusion-segregation/ 440
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 4 today to have a “disparate impact” on classes protected by the Fair Housing Act. For example, the 1926 case Village of Euclid v. Amber Realty Co. (272 U.S. 365) supported the segregation of residential, business, and industrial uses, justifying separation by characterizing apartment buildings as “mere parasite(s)” with the potential to “utterly destroy” the character and desirability of neighborhoods. At that time, multifamily apartments were the only housing options for people of color, including immigrants.

The Federal Fair Housing Act was not enacted until nearly 60 years after the first racial zoning ordinances appeared in U.S. cities. This coincided with a shift away from federal control over low-income housing toward locally-tailored approaches (block grants) and market-oriented choice (Section 8 subsidies)—the latter of which is only effective when adequate affordable rental units are available.

History of segregation in Half Moon Bay. Founded in 1875, Half Moon Bay has a rich history of fishing and agriculture that has lasted centuries. The area was originally home to the Muwekma Ohlone Tribe, where fishing and agriculture supported the local native population. The abundance of fish and shellfish were crucial for the Ohlone tribe. These resources proved useful to Spanish colonial settlers when they reached the region in the late 1700s . The area, then known as “Spanishtown”, was an agricultural production center for Mission San Francisco de Asís approximately 20 miles north.

American settlers continued Half Moon Bay’s agriculture uses as the rest of the region moved away from agriculture in favor of suburban development. Entrepreneurs saw an opportunity to highlight Half Moon Bay’s open space and scenic coastlines to attract tourists to the City.

Over the decades, City leaders have maintain Half Moon Bay’s tourist appeal by preserving historic structures, open space near the coast and low intensity land uses. Today, tourism continues to be a major economic force as highlighted by the Ritz-Carlton, Half Moon Bay.

Opened in 2001, the Ritz-Carlton has become the largest accommodation for tourists and the largest employer in Half Moon Bay, accounting for 5.26% of the workforce.

Half Moon Bay’s current land use includes a number of wineries and farms that exist among single-family homes and local businesses. It stands out a unique coastal agricultural resource in a largely developed San Mateo County. Half Moon Bay hosts the Mavericks Big Wave surfing competition, Art & Pumpkin Festival, and many other festivals that attract international visitors. The tension between coastal preservation, tourist-focused uses serving the Bay Area region, farming uses serving local and global agricultural providers, and the single-family and local commercial uses that are traditionally found in similarly-sized California cities, lead to unique tensions where use-based zoning segregations (between conservation, tourism, agriculture, and residential/commercial uses) have dramatic impacts on social interactions within the City. Increased farmworker housing, for example, can impact local housing costs in one direction while hotel-to-residential conversions can have a more significant impact than similar projects in larger jurisdictions. 441
City of Half Moon Bay Housing Element – Fourth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 5 Figure D-1: Major Public and Legal Actions that Influence Fair Access to Housing 442
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 6 Maps and data referenced in this section. Throughout this section, there are references to maps created by HCD to support the AFFH and data tables created by HCD, the Association of Bay Area Governments (ABAG), and the consultant team. Those maps and tables appear in an Appendix and follow the organization of this section and the state guidance. The maps, in particular, are useful in demonstrating how Half Moon Bay compares with the county and region overall in offering housing choices and access to opportunity.

Report content and organization. This Fair Housing Assessment follows the April 2021 State of California State Guidance for AFFH. It incorporates the newest HCD maps, released in March 2023.

Section I. Fair Housing Enforcement and Outreach Capacity reviews lawsuits/enforcement actions/complaints against the jurisdiction; compliance with state fair housing laws and regulations; and jurisdictional capacity to conduct fair housing outreach and education.

Section II. Integration and Segregation identifies areas of concentrated segregation, degrees of segregation, and the groups that experience the highest levels of segregation.

Section III. Access to Opportunity examines differences in access to education, transportation, economic development, and healthy environments.

Section IV. Disparate Housing Needs identifies which groups have disproportionate housing needs including displacement risk.

PRIMARY FINDINGS:

FAIR HOUSING CHALLENGES AND CONTRIBUTING FACTORS
This section summarizes the primary findings from the Fair Housing Assessment for the City of Half Moon Bay including the following sections: fair housing enforcement and outreach capacity, integration and segregation, access to opportunity, disparate housing needs, and contributing factors and the city’s fair housing action plan.

Half Moon Bay’s primary fair housing challenges are:
• Some racial and ethnic minority populations are disproportionately impacted by low household incomes, and overcrowding, and are more likely to be denied a home mortgage loan (High Priority)
• Educational outcomes vary by racial and ethnic group (Medium Priority) A complete list of fair Housing Challenges and Contributing Factors are listed below in detail. 443
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 7 It also identifies areas where fair housing challenges exist and the factors contributing to those challenges.
 One fair housing complaint was filed in Half Moon Bay from 2017 to 2021. In the resident survey conducted for this AFFH, 26% of Half Moon Bay residents said they had experienced housing discrimination. This is higher than in the county overall (19%). In the majority of cases, the discrimination took place in the past 5 years. It is unclear if this low number of complaint filings is due to the lack of discriminatory activity in the City or due to lack of resident knowledge about fair housing rights or both. Regardless, the City should ensure that residents can easily find fair housing information when they need it.  The City could improve the accessibility of fair housing information on their website and resources for residents experiencing housing discrimination by providing a link to HUD and/or State of California fair housing laws as well as information about how to file a fair housing complaint.
 The City of Half Moon Bay is less racially/ethnically diverse than the county overall, primarily driven by a lower representation of Asian residents. However, the city has a slightly higher proportion of Hispanic residents (30%) than the county (24%).  Racial and ethnic segregation in Half Moon Bay is low overall. The highest level of segregation (although still low) in Half Moon Bay is between Black/African American and White residents (DI of .244). This index declined significantly between 2000 and 2020.

Conversely, between 2000 and 2020, Hispanic residents in Half Moon Bay became more segregated (.207 DI as of 2020).
 Because Half Moon Bay is fairly small, the entire city falls within the “moderate resource area” designation (Figure III-13) in terms of its opportunity score, with most jobs and schools located within the central part of the city, accessible to all neighborhoods.
 Fair housing challenge: Some racial and ethnic minority populations are disproportionately impacted by low household incomes, and overcrowding, and are more likely to be denied a home mortgage loan compared to the non-Hispanic White population in the City of Half Moon Bay. Specifically,
 Hispanic, Asian, and Other/Multiple race households have lower incomes and higher poverty rates than non-Hispanic White households (Figures II-4 and II-5).  Hispanic, Asian, and Other/Multiple race households, as well as large families, are more likely than non-Hispanic White households to be cost-burdened, though overall rates of cost burden are slightly lower in Half Moon Bay than the county overall (Figures IV-8, IV-11, and IV-12).
444
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 8  Hispanic and Other/Multiple race households are more likely than non-Hispanic White households to experience overcrowding (Figure IV-17). Low- and moderateincome households are also more likely to be overcrowded (Figure IV-18).  People who identify as American Indian or Alaskan Native, Black/African American, and Hispanic are overrepresented in the homeless population compared to their share of the general population countywide (Figure IV-22).  Hispanic and American Indian/Alaska Native households have the highest denial rates for mortgage loan applications in Half Moon Bay in 2018 and 2019 (Figure IV33).

Contributing factors include: Lower incomes and higher poverty rates among residents of color; lack of affordable housing relative to household incomes; and high debt-toincome ratios among applicants of color who are denied mortgage loans.  Residents with a disability make up 10% of the population in Half Moon Bay compared to 8% in the county (Figure III-21). The census tract comprising the southern half of Half Moon Bay has a slightly higher share of the population living with a disability (between 10% and 20%), compared with less than 10% in the northern portion of the city.  The school district serving Half Moon Bay educates a larger share of higher needs students than peers in the county. Accordingly, Cabrillo Unified, which serves Half Moon Bay and portions of unincorporated San Mateo County, has the highest share of migrant students in the county (3%), the second highest share of homeless students (2% of students experiencing homelessness), and a high share of students who qualify for reduced lunch (37% compared to 29% countywide).
 Educational outcomes vary by racial and ethnic group, and the school district could improve proficiency gaps and differences in college readiness and dropout rates.

Specifically,
 Just 16% of Hispanic students and 38% of Filipino students met or exceeded math testing standards, compared to 54% of White students and 65% of Asian students.  Just 28% of Hispanic students and 54% of Filipino students met or exceeded math testing standards, compared to 71% of White students and 78% of Asian students.  Cabrillo Unified had one of the lowest rates of graduates who met college admission standards at 41%, and Hispanic students in the district were even less likely to meet such standards, with a rate of 28%.
 Hispanic (8%) and Black (6%) students also had the highest dropout rates in the district.

Contributing factors: Disparate outcomes by race and ethnicity are unfortunately common across communities due to under-resourced families and educational 445
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 9 institutions and the multiple stresses that impact lower-income students and their families, who are proportionally more likely to be from racial and ethnic minority groups.
 Half Moon Bay’s housing stock accommodates a variety of income levels—more so than many other small communities in the County:
 The ownership market in Half Moon Bay is on par with the county overall but has a slightly higher proportion of homes under $500,000, which tend to be located in mobile home parks. More than 8% of the City’s housing stock is manufactured homes (Figure IV-4).
 The rental distribution in Half Moon Bay reflects a more affordable rental market than San Mateo County overall (Figure IV-6).
 Permit data (Figure IV-2) suggest the market is serving above moderateincome households but the city was also able to accommodate income restricted development serving very low-income households.

RECOMMENDED FAIR HOUSING ACTION PLAN
 Although Half Moon Bay has many housing resources and services listed on its website, the City should bolster the information to make it easier for residents to find information about their fair housing rights and for landlords to find information about their fair housing responsibilities. Recommended resources include providing a link to HUD and/or State of California fair housing laws as well as information about how to file a fair housing complaint. Program 4-3 supports this recommendation.  Half Moon Bay should target its new housing development to meet the needs of residents who face the greatest housing challenges, including Hispanic, Filipino, Asian, and Other/Multiple race households. The City should require affirmative marketing of developers building those units. The goal of affirmative marketing is to expand housing opportunities to attract income eligible populations and demographic groups who might not otherwise apply or be considered because of past, historic discrimination. Program 4-3 supports this recommendation.
 Half Moon Bay should make a concerted effort to retain a housing stock that accommodates a wider variety of income levels than many other communities in San Mateo County. The City should invest in preservation of existing affordable housing to sustain its relative affordability. Program 2-1 and others support this recommendation. 446
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 10  The City should invest in community development and services to improve educational and employment outcomes of its lowest-income residents, as well as affordable housing opportunities. The City’s Town Center, including its Downtown core, is considered a high resource area with schools, services, and stores. Transit improvements to improve access via public transit, bike, and pedestrian as well as focused affordable housing opportunities for this area should be prioritized to support existing and future residents. The City is mindful of these needs and is supporting them by establishing the Coastside Opportunity Center and other efforts to expand providing educational resources described below. Furthermore, numerous capital improvements are planned to improve pedestrian and bicycle access throughout the Town Center.  City leadership should advocate for more educational resources to meet the needs of Half Moon Bay students with extenuating circumstances. The Boys and Girls Club of the Coastside is significantly important to middle and high school students who suffer from housing insecurity and other significant economic stresses. City staff sought direct input from the Boys and Girls Club director in a stakeholder interview for the Cycle 6 Housing Element. Also, as part of the City’s Coastside Recovery Initiative’s focus on economic and community recovery from the COVID pandemic, the deep need for education and workforce development came to light. The City is opening the Coastside Opportunity Center in 2023 and seeking a satellite location for the College of San Mateo Community College. These resources are highly relevant to this need.

SECTION I.

FAIR HOUSING ENFORCEMENT AND OUTREACH CAPACITY
This section discusses fair housing legal cases and inquiries, fair housing protections and enforcement, outreach capacity, and jurisdiction compliance with relevant State laws.

In preparing this AFFH technical report, Half Moon Bay staff, through the City’s participation in 21 Elements, engaged in discussion with local fair housing organizations (Legal Aid of San Mateo County and Project Sentinel) to learn about fair housing trends and concerns, as well as to discuss best practices in AFFH. Following this discussion, the 21 Elements team contacted local fair housing organizations to obtain local data on fair housing complaints and lawsuits beyond what was available in HCD and HUD datasets. Consultants also obtained and analyzed data from HUD. These datasets were compared for duplicate cases and analyzed and appear in the graphics and tables in this section.

Fair housing legal cases and inquiries. California fair housing law extends beyond the protections in the Federal Fair Housing Act (FHA). In addition to the FHA protected classes— 447
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 11 race, color, ancestry/national origin, religion, disability, sex, and familial status—California law offers protections for age, sexual orientation, gender identity or expression, genetic information, marital status, military or veteran status, and source of income (including federal housing assistance vouchers).

The California Department of Fair Employment in Housing (DFEH) was established in 1980 and is now the largest civil rights agency in the United States. According to their website, the DFEH’s mission is, “to protect the people of California from unlawful discrimination in employment, housing and public accommodations (businesses) and from hate violence and human trafficking in accordance with the Fair Employment and Housing Act (FEHA), Unruh Civil Rights Act, Disabled Persons Act, and Ralph Civil Rights Act”.6 DFEH receives, evaluates, and investigates fair housing complaints. DFEH plays a particularly significant role in investigating fair housing complaints against protected classes that are not included in federal legislation and therefore not investigated by HUD. DFEH’s website provides detailed instructions for filing a complaint, the complaint process, appealing a decision, and other frequently asked questions.7 Fair housing complaints can also be submitted to HUD for investigation.

Additionally, San Mateo County has a number of local enforcement organizations including Project Sentinel, the Legal Aid Society of San Mateo County, and Community Legal Services of East Palo Alto. These organizations receive funding from the County and participating jurisdictions to support fair housing enforcement and outreach and education in the County.

From 2017 to 2021, 57 fair housing complaints in San Mateo County were filed with the U.S. Department of Housing and Urban Development (HUD)—just 1 complaint was in the City of Half Moon Bay. Most complaints cited disability status as the bias (56%) followed by race (19%), and familial status (14%).

Countywide, no cause determination was found in 27 complaints followed by successful conciliation or settlement with 22 complaints. Fair housing inquiries in 2020 were primarily submitted to HCD from the City of San Mateo, Redwood City, Daly City, and Menlo Park.

Fair housing complaints filed with HUD by San Mateo County residents have been on a declining trend since 2018, when 18 complaints were filed. In 2019, complaints dropped to 5, increased to 11 in 2020, and reached 6 by mid-2021.

Nationally, the National Fair Housing Alliance (NFHA) reported a “negligible” decrease in the number of complaints filed between 2019 and 2020. The primary bases for complaints 6 https://www.dfeh.ca.gov/aboutdfeh/ 7 https://www.dfeh.ca.gov/complaintprocess/ 448
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 12 nationally were nearly identical to San Mateo County’s: disability (55%) and race (17%).

Familial status represented 8% of complaints nationally, whereas this basis comprised 14% of cases in the county.

NFHA identifies three significant trends in 2020 that are relevant for San Mateo County:
 First, fair lending cases referred to the Department of Justice from federal banking regulators have been declining, indicating that state and local government entities may want to play a larger role in examining fair lending barriers to homeownership.  Second, NFHA identified a significant increase in the number of complaints of harassment—1,071 complaints in 2020 compared to 761 in 2019.  Finally, NFHA found that 73% of all fair housing complaints in 2020 were processed by private fair housing organizations, rather than state, local, and federal government agencies—reinforcing the need for local, active fair housing organizations and increased funding for such organizations.8
In the resident survey conducted for this AFFH, 26% of Half Moon Bay residents said they had experienced housing discrimination. This is higher than in the county overall (19%). In the majority of cases, the discrimination took place in the past 5 years.

Residents responded by moving (36%), contacting a fair housing organization (36%), or doing nothing/being unsure of what to do (27%).

A similar question asked if residents had ever been denied housing. Seventeen percent of Half Moon Bay respondents said they had been denied housing because they had children.

Ownership denials were more prevalent, with 23% saying that the real estate agent refused to accommodate a disability, and 23% saying they were denied a mortgage loan—mostly due to a low income and/or lack of credit.

8 https://nationalfairhousing.org/2021/07/29/annual-fair-housing-report-shows-increase-in-housing-harassment/ 449
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 13 Figure D-2: Fair Housing Complaints and Inquiries

450
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 14 Outreach and capacity. The City of Half Moon Bay is a small jurisdiction with a small staff, which limits its ability to actively enforce fair housing, investigate complaints, and obtain remedies. The City has historically relied on local nonprofit and state agencies, as well as HUD, who specialize in that work to be partners in fair housing enforcement and outreach.

When the City receives a fair housing inquiry from a resident, it refers them to local fair housing organizations, the state, and HUD. This approach provides a more effective method of ensuring that residents receive accurate and timely advice and resources.

To that end, the City provides resources on fair housing rights and housing options through its website. 9 That site does a great job outlining local housing resources (in both English and Spanish). The City reviewed that site in the context of preparing this AFFH and acknowledges that the accessibility of fair housing information could be improved—for example, by including direct links to HUD and/or State of California fair housing laws and detailed information about how to file a fair housing complaint.

Compliance with State law. The City of Half Moon Bay is compliant with the following state laws that promote fair and affordable housing. The city has not been alleged or found in violation of the following:
 State Density Bonuses and Other Incentives Law (Gov. Code. Title 7. Division 1. Chapter

4.3 Density Bonuses and Other Incentives, amended and effective January 1, 2021);  Housing Accountability Act (Gov Code Section 65589.5) requiring adoption of a Housing Element and compliance with RHNA allocations;
 No Net Loss Law (Gov Code Section 65863) requiring that adequate sites be maintained to accommodate unmet RHNA allocations, including among income levels;  Least Cost Zoning Law (Gov Code Section 65913.1);
 Excessive Subdivision Standards Law (Gov Code Section 65913.2);  Limits on Growth Controls Law (Gov Code Section 65589.5).

Housing specific policies enacted locally. The City of Half Moon Bay identified the following local policies that contribute to the regulatory environment for affordable housing development in the city.
9 https://www.half-moon-bay.ca.us/607/HMB-Housing-Resources-and-Services 451
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 15 Local policies in place to encourage
housing development.
 Reduced Parking Requirements
 Housing Overlay Zone
 Other Anti-Displacement Strategies
 In-Lieu Fees (Inclusionary Zoning)
 Tenant-Based Assistance
 Second Unit Ordinance
 Emergency Shelters
 Affordable Housing Complexes
Local barriers to affordable housing
development.
 Voter initiative that limits growth
and thereby also restricts
multifamily and/or larger
developments
 Presence of coastal hazards that
must be avoided.
 Presence of environmental
resources that must be protected.

Local policies that are NOT in place but
would provide the best outcomes in
addressing housing shortages.
 Development impact fee waivers
 Updating the BMR ordinance to
include rental units and a lower
threshold for project eligibility.

Local policies that are NOT in place, but
have potential Council interest to explore.
 Affordable housing impact/linkage fee
on new residential and commercial
development
 Community land trusts
 First source hiring ordinances
 Fair housing legal services
 Acquisition of affordable units with
expiring subsidies
 Acquisition of unsubsidized properties
with affordable rents
 Dedicating surplus land for affordable
housing
Local policies in place to mitigate or
prevent displacement of low-income
households.
 Mobile home relocation and
displacement prevention
 Condominium conversion
regulations
 Inclusionary zoning
 Living wage employment ordinances
 Promoting streamlined processing
of ADUs
 Eviction protection ordinances
 Housing counseling
452
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 16 According to the California Department of Housing and Community Development AFFH Data Viewer (HCD data viewer), the City of Half Moon Bay does not have any public housing buildings. However, the city does have 371 publicly assisted affordable units (funded by LIHTC, USDA, and/or CalHFA projects) as well as one census tract with a moderate share of renters using housing vouchers (15% to 30%)—see Figure I-7. The presence of housing voucher users indicates available rental supply to house these residents and a lack of exclusionary behavior from landlords, at least in the southern portion of the city.

Compared to the region overall—see Figure I-8—Half Moon Bay has a relatively higher share of rental units in which voucher holders live. In the southern portion of Half Moon Bay, between 15% and 30% of rental units house voucher holders. This share is positive, indicating neither too few vouchers (i.e., exclusionary practices) nor too many vouchers (i.e., segregatory practices).

SECTION II. INTEGRATION AND SEGREGATION
This section discusses integration and segregation of the population by protected classes including race and ethnicity, disability status, familial status, and income status. The section concludes with an analysis of racially and ethnically concentrated areas of poverty and affluence.

Integration and Segregation
“Integration generally means a condition in which there is not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a particular type of disability when compared to a broader geographic area.

Segregation generally means a condition in which there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area.”
Source: California Department of Housing and Community Development Guidance, 2021, page 31.

Race and ethnicity. The City of Half Moon Bay is less racially/ethnically diverse than the county overall, primarily driven by a lower representation of Asian residents. In Half Moon Bay, 61% of the population identifies as non-Hispanic White residents compared to just 39% in San Mateo County. The city also has a slightly higher proportion of Hispanic residents 453
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 17 (30%) than the county (24%) but a much lower portion of Asian residents (7% in the city compared to 30% countywide).

The racial/ethnic composition of the city has changed little over the past 10 years, other than a slight proportional increase in Asian residents (from 4% in 2010 up to 7% in 2019).

Geospatially, all census tracts in Half Moon Bay are White majority census tracts (Figure II9).1011 Compared to the county and region (Figures II-12 and II-13), Half Moon Bay is more likely to be White segregated; it does not exhibit the moderate to high segregation of residents of color found in many jurisdictions in the county and region. Very few areas in the county and region are identified as integrated (Figure II-13). Half Moon Bay’s diversity index did not change between 2010 and 2018 (Figures II-14 and II-15).

Racial and ethnic minority populations generally have higher rates of poverty and lower household incomes compared to the non-Hispanic White population in Half Moon Bay (and the county overall).

Dissimilarity and isolation indices. ABAG and UC Merced completed an analysis of segregation in Half Moon Bay. Several indices were used to assess segregation in the city and determine how the city differs from patterns of segregation and integration in the region overall.

The Dissimilarity Index, or DI, is a common tool that measures segregation in a community.

The DI is an index that measures the degree to which two distinct groups are evenly distributed across a geographic area. The DI represents the percentage of a group’s population that would have to move for each area in the county to have the same percentage of that group as the county overall.

DI values range from 0 to 100—where 0 is perfect integration and 100 is complete segregation. Dissimilarity index values between 0 and 39 generally indicate low segregation, values between 40 and 54 generally indicate moderate segregation, and values between 55 and 100 generally indicate a high level of segregation. 10 Majority census tracts show the predominant racial or ethnic group by tract compared to the next most populous.
11 Redlining maps, otherwise known as Home Owners’ Loan Corporation (HOLC) maps, are not available for San Mateo County.
454
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 18 The isolation index is interpreted as the probability that a randomly drawn minority resident shares an area with a member of the same minority, it ranges from 0 to 100 and higher values of isolation tend to indicate higher levels of segregation.

The primary findings from that analysis included:
 In Half Moon Bay, White residents are more likely than any other residents to live in neighborhoods where they are less likely to come into contact with other racial groups.  Racial and ethnic segregation in Half Moon Bay is low overall. The highest level of segregation (although still low) in Half Moon Bay is between Black/African American and White residents (DI of .244). This index declined significantly between 2000 and 2020.

Conversely, between 2000 and 2020, Hispanic residents in Half Moon Bay became more segregated (.207 DI as of 2020).
 By income, moderate-income residents are the most segregated compared to other income groups. Income segregation in Half Moon Bay decreased between 2010 and 2015.

Disability status. The share of the population living with at least one disability is 10% in Half Moon Bay compared to 8% in San Mateo County. The census tract comprising the southern half of Half Moon Bay has a 10% to 20% share of the population living with a disability, compared with less than 10% in the northern portion of the city. Geographic concentrations of people living with a disability may indicate the area has ample access to services, amenities, and transportation that support this population.

Familial status. Married couple households are the most common household type in Half Moon Bay, representing about 60% of all households. However, the city is home to more single-person households than the county, with 26% of households compared to 22% in the County, and there are fewer families with children in the city (26% vs 33%).

Familial status can indicate specific housing needs and preferences. A larger number of nonfamily or single-person households indicates a higher share of seniors living alone, young adults living alone or with roommates, and unmarried partners. Higher shares of nonfamily households indicate an increased need for one- and two-bedroom units.

The majority of married couple households (78%) and residents living alone (70%) live in owner-occupied housing. A slim majority of single-parent households are owners while the majority of non-family households are renters.

The number of housing units available by number of bedrooms and tenure is broadly consistent with the familial status of the households that live in Half Moon Bay. 455
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 19 Household income. The household income distribution by percent of area median income (AMI) in the City of Half Moon Bay is similar to the county and the Bay Area overall. The majority of census block groups in the city have median incomes over $125,000, with only very small portions of the city reflecting median incomes closer to the 2020 state median income of $87,100 for a family of four. Poverty rates are below 10% in all census tracts covering Half Moon Bay.

Figure D-3: Segregation and Integration
Racially or ethnically concentrated areas of poverty and affluence. Racially Concentrated Area of Poverty or an Ethnically Concentrated Area of Poverty (R/ECAP) and Racially Concentrated Areas of Affluence (RCAAs) represent opposing ends of the segregation 456
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 20 spectrum from racially or ethnically segregated areas with high poverty rates to affluent predominantly White neighborhoods. Historically, HUD has paid particular attention to R/ECAPs as a focus of policy and obligations to AFFH. Recent research out of the University of Minnesota Humphrey School of Public Affairs argues for the inclusion of RCAAs to acknowledge current and past policies that created and perpetuate these areas of high opportunity and exclusion.12
It is important to note that R/ECAPs and RCAAs are not areas of focus because of racial and ethnic concentrations alone. This study recognizes that racial and ethnic clusters can be a part of fair housing choice if they occur in a non-discriminatory market. Rather, R/ECAPs are meant to identify areas where residents may have historically faced discrimination and continue to be challenged by limited economic opportunity, and conversely, RCAAs are meant to identify areas of particular advantage and exclusion.

R/ECAPs
HCD and HUD’s definition of a Racially/Ethnically Concentrated Area of Poverty is:
 A census tract that has a non-White population of 50% or more (majority-minority) or, for non-urban areas, 20%, AND a poverty rate of 40% or more; OR  A census tract that has a non-white population of 50% or more (majority-minority) AND the poverty rate is three times the average tract poverty rate for the County, whichever is lower.

Source: California Department of Housing and Community Development Guidance, 2021.

For this study, the poverty threshold used to qualify a tract as an R/ECAP was three times the average census tract poverty rate countywide—or 19.1%. In addition to R/ECAPs that meet the HUD threshold, this study includes edge or emerging R/ECAPs which hit two-thirds of the HUD defined threshold for poverty—emerging R/ECAPs in San Mateo County have two times the average tract poverty rate for the county (12.8%).

In 2010 three census tracts qualified as R/ECAPs (19.4% poverty rate) in the county and 11 that qualify as edge R/ECAPs (13% poverty rate). None of the R/ECAPs were located in Half Moon Bay in 2010.
12 Goetz, E. G., Damiano, A., & Williams, R. A. (2019). Racially Concentrated Areas of Affluence: A Preliminary Investigation. Cityscape: A Journal of Policy Development and Research, 21(1), 99–124 457
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 21 In 2019 two census tracts qualified as R/ECAPs (19.1% poverty rate) in the county and 14 that qualify as edge R/ECAPs (12.8% poverty rate)—which means they are majority minority and have a poverty rate two times higher than the countywide census tract average. None of the R/ECAPs or edge R/ECAPs are located in Half Moon Bay.

RCAAs. HCD’s definition of a Racially Concentrated Area of Affluence is:
 RCAAs are census tracts with a median income 1.25 times higher than in the region and a White population of 1.5 times higher than in the region. A census tract that has a percentage of total white population that is 1.25 times higher than the average percentage of total white population in the given COG region, and a median income that was 2 times higher than the COG AMI.

Figure II-36 shows RCAAs for Half Moon Bay; these are indicated in beige. Like all surrounding areas, Half Moon Bay is comprised entirely of RCAAs. This is a factor of the census tracts’ (and Half Moon Bay’s) low poverty rate, high-income, and White population. There is little differentiation among census tracts in terms of income (all are relatively high-income) and moderate differences in poverty.

Additional RCAA and RECAP analysis is provided in C: Housing Resources in the “Racially and Ethnically Concentrated Areas of Poverty and Affluence” beginning on page C-57.

Local Data and Knowledge. Half Moon Bay’s agricultural roots have brought a diverse pool of seasonal and permanent farmworkers to the region. Half Moon Bay is one of the few active agricultural communities in San Mateo County, and the high stress of the physical labor, combined with low wages and the high cost of living in the region, isolated from a wealthier and whiter community, are a unique issue in the City that can be difficult to capture with traditional statistical analyses.

In January 2023, a mass shooting occurred on a farm in Half Moon Bay. The suspect in the shooting killed seven people and injured one. The shooting had a stark impact on Half Moon Bay’s farmworker community, particularly among Chinese farmworkers who often feel isolated from the Bay Area’s larger Chinese community. “Most of the time, [these farmworkers] are stationed at the farm. They live at the farm. They eat at the farm…most of them have very limited social interaction with the people outside,” said Sao Leng U, the director of social services at Self-Help for the Elderly, in a January 22, 2024, interview with KQED.

SECTION III. ACCESS TO OPPORTUNITY
This section discusses disparities in access to opportunity among protected classes including access to quality education, employment, transportation, and environment. Additional 458
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 22 analysis is provided in C: Housing Resources under “Access to Opportunity (TCAC)” beginning on page C-59.

Access to Opportunity
“Access to opportunity is a concept to approximate place-based characteristics linked to critical life outcomes. Access to opportunity oftentimes means both improving the quality of life for residents of low-income communities, as well as supporting mobility and access to ‘high resource’ neighborhoods. This encompasses education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, and other opportunities, including recreation, food and healthy environment (air, water, safe neighborhood, safety from environmental hazards, social services, and cultural institutions).”
Source: California Department of Housing and Community Development Guidance, 2021, page 34.

The California Tax Credit Allocation Committee (TCAC) in collaboration with HCD developed a series of opportunity maps that help to identify areas of the community with good or poor access to opportunity for residents. These maps were developed to align funding allocations with the goal of improving outcomes for low-income residents. Opportunity scores are presented on a scale from zero to one and the higher the number, the more positive the outcomes.

In addition to the HCD provided data, the resident survey conducted for this AFFH asked residents about their greatest neighborhood challenges. For Half Moon Bay residents, transportation-related items ranked the highest, with nearly one in five residents reporting challenges accessing public transportation; another one in five said that lack of sidewalks, walking areas, and lighting was a challenge.

Overall access to opportunity. Figure III-6 shows the TCAC Opportunity Areas Economic Score for Half Moon Bay and the region. All areas of Half Moon Bay are shown to produce moderate economic outcomes for residents; there is no variance in opportunity by geography.

Compared to the region overall, Half Moon Bay offers opportunity levels similar to Pacifica, Daly City, areas south of the City of San Francisco, and the City of Santa Clara. Opportunity is in between that offered by most jurisdictions—not the highest, but not the lowest. This is partially due to the city’s isolated location. As shown in the jobs proximity maps (Figures III9 and III-10), Half Moon Bay residents must commute long distances to job centers. 459
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 23 In June 2023, a new microtransit system operated by the County’s bus service agency, SamTrans, was added within Half Moon Bay and surrounding Coastside communities. This service provides localized, on-demand pickups via a shared-ride platform called Ride Plus.

Transit to and from major job centers east of Half Moon Bay are not currently included in the Ride Plus service area; however, staff believes this service will increase access to local opportunities for many residents, especially for low-income residents with limited transportation options and older adults, including residents of the Canada Cove Mobile Home Park. Users can take advantage of the service via an app or by setting up rides over the phone.

Education. The City of Half Moon Bay is served by the Cabrillo Unified School District (for both elementary and high school). Cabrillo Unified also serves a large portion of unincorporated county outside of Half Moon Bay. Education performance data are not available strictly at the city level so the following analysis focuses on the Cabrillo Unified School District overall.

School enrollment across all districts serving San Mateo County declined slightly (1%) between 2010 and 2020. Enrollment losses were more severe in Cabrillo Unified, where enrollment declined by 12% over the same period. (These declines do include reductions due to the pandemic).

Enrollment by race and ethnicity for Cabrillo Unified diverges from the countywide distribution—and the overall racial/ethnic composition of Half Moon Bay. Cabrillo Unified has a larger proportion of Hispanic students (52%) compared to the countywide student population (38%) and the resident representation of Half Moon Bay (30%).

Compared to San Mateo County, Cabrillo Unified also has more White students (40% compared to 26% countywide) and a smaller proportion of Asian, Black, Filipino, Pacific Islander, and Other/Multiple race students.

Cabrillo Unified has the highest share of migrant students in the county (3%), along with the second highest share of homeless students (2% of students experiencing homelessness). The district also has a high share of students who qualify for reduced lunch compared to the countywide proportion (37% compared to 29% countywide).

Disparities in achievement are stark in Cabrillo Unified for Hispanic and Filipino students:
 Just 16% of Hispanic students and 38% of Filipino students met or exceeded math testing standards, compared to 54% of White students and 65% of Asian students.  Just 28% of Hispanic students and 54% of Filipino students met or exceeded English testing standards, compared to 71% of White students and 78% of Asian students.

Many high schoolers in the county met admission standards for a University of California (UC) or California State University (CSU) school. Of the high school districts in San Mateo 460
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 24 County, Cabrillo Unified had one of the lowest rates of graduates who met such admission standards at 41%. Hispanic students in the Cabrillo Unified School District were less likely to meet the admission standards, with a rate of 28%.

Cabrillo Unified has relatively moderate dropout rates—6% of students—compared to other districts in the county. Hispanic (8%) and Black (6%) students had the highest dropout rates in the district.

Employment. The top three industries by number of jobs in the City of Half Moon Bay include arts and recreation services, construction, health, and educational services. The city has a slightly lower job-to-household ratio than the county at 1.35 and 1.59 respectively—which means there are fewer employment opportunities per household in the City of Half Moon Bay. The city also has a lower unemployment rate of 4.1% compared to the county at 5.9%.

HUD’s job proximity index shows the City of Half Moon Bay as moderate: On a scale from zero to 100 where 100 is the closest proximity to jobs the majority of the city scores between 40 and 60.

Despite having a moderate job proximity index, very few jobs in Half Moon Bay are accessible to residents by public transit, meaning a large portion of residents are likely commuting to work. Less than 46,000 jobs are located within 45 minutes of the city (Figure III-10). Longer commutes and limited opportunities for public transportation likely have a disproportionate impact on lower-income households that are not able to afford a car.

Transportation. The San Mateo County Transit District acts as the administrative body for transit and transportation programs in the county including SamTrans and the Caltrain commuter rail. SamTrans provides bus services in San Mateo County, including Redi-Wheels paratransit service.

Overall, Half Moon Bay has a housing and transportation index of 50% to 75% and does not have high quality transit stops for residents needing access to public transportation. High quality transit stops are largely concentrated along the east coast of San Francisco Bay.

In 2018, the Metropolitan Transportation Commission (MTC), which covers the entire Bay Area, adopted a coordinated public transit and human services transportation plan. While developing the coordinated plan, the MTC conducted extensive community outreach about transportation within the area. That plan—which was developed by assessing the effectiveness of how well seniors, persons with disabilities, veterans, and people with low incomes are served—was reviewed to determine gaps in services in San Mateo and the county overall. Below is a summary of comments relevant to San Mateo County; no comments specific to Half Moon Bay were included in the report. 461
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 25 “San Mateo’s [Paratransit Coordinating Council] PCC and County Health System, as well as the Peninsula Family Service Agency provided feedback. The most common themes expressed had to do with pedestrian and bicycle needs at specific locations throughout the county, though some covered more general comments such as parked cars blocking sidewalk right-of-way and a desire for bike lanes to accommodate motorized scooters and wheelchairs. Transportation information, emerging mobility providers, and transit fares were other common themes. While some comments related to the use of car share, transportation network companies (TNCs), or autonomous vehicles as potential solutions, other comments called for the increased accessibility and affordability of these services in the meantime.”13 A partnership between the World Institute on Disability and the MTC created the research and community engagement project TRACS (Transportation Resilience, Accessibility & Climate Sustainability). The project’s overall goal is to, “stimulate connection and communication between the community of seniors and people with disabilities together with the transportation system– the agencies in the region local to the San Francisco Bay, served by MTC.”14
As part of the TRACS outreach process, respondents were asked to share their compliments or good experiences with MTC transit. One respondent who had used multiple services said, “it is my sense that SamTrans is the best Bay Area transit provider in terms of overall disability accommodation.”
The San Mateo County Transit District updated its Mobility Plan for Older Adults and People with Disabilities in 2018. According to the district, the county’s senior population is expected to grow more than 70% over the next 20 years and the district is experiencing unprecedented increases in paratransit ridership. The plan is targeted at developing effective mobility programs for residents with disabilities and older adults including viable alternatives to paratransit, partnerships, and leveraging funding sources.15 MTC also launched Clipper START—an 18-month pilot project— in 2020 which provides fare discounts on single transit rides for riders whose household income is no more than double the federal poverty level.16
13 https://mtc.ca.gov/sites/default/files/MTC_Coordinated_Plan.pdf 14 https://wid.org/transportation-accessibility/ 15https://www.samtrans.com/Planning/Planning_and_Research/Mobility_Plan_for_Older_Adults_and_Peopl e_with_Disabilities.html 16 https://mtc.ca.gov/planning/transportation/access-equity-mobility/clipperr-startsm 462
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 26 In the resident survey conducted to support this AFFH, lack of access to transit was the top neighborhood challenge reported by residents: 18% identified this as a challenge which is higher than the county proportion (14%).

Environment. TCAC’s opportunity areas environmental scores are based on the CalEnviroScreen 3.0 indicators, which identify areas disproportionately vulnerable to pollution sources such as ozone, PM2.5, diesel PM, pesticides, toxic release, traffic, cleanup sites, groundwater threats, hazardous waste, impaired water bodies, and solid waste sites.

Generally, all census tracts in Half Moon Bay score poorly on environmental outcomes, as measured by the TCAC Environmental Score and CalEnviroScreen 3.0 maps. However, the city scores relatively high compared to other areas of San Mateo County on the California Healthy Places Index (HPI) developed by the Public Health Alliance of Southern California (PHASC).

The HPI includes 25 community characteristics in eight categories including economic, social, education, transportation, neighborhood, housing, clean environment, and healthcare.17 Disparities in access to opportunity. Countywide data show that non-Hispanic White residents are more likely to live in high resource areas compared to racial and ethnic minorities. However, Half Moon Bay, in its entirety is considered a “moderate resource area” which means there are no apparent opportunity disparities among groups within the city.

The Social Vulnerability Index (SVI) provided by the Center for Disease Control (CDC) —ranks census tracts based on their ability to respond to a disaster—includes four themes of socioeconomic status, household composition, race or ethnicity, and housing and transportation. The SVI classifies Half Moon Bay as having relatively low vulnerability.

Despite this designation, local knowledge paints a different picture. A range of environmental hazards, inherent to the coastal setting and intensified by climate change, affect the entire city. These include the city’s adjacency to wildland fire risk areas; flood hazards due to numerous water courses, sea level rise, and potential inundation from tsunami or dam failure; seismic and geological conditions including liquefaction and landslide potential; and coastal and watercourse erosion. While generally, these hazards affect the city as a whole, unprecedented Pilarcitos Creek flooding in January 2023 impacted one of the city’s lower-income multi-family neighborhoods.18 Limited short-term relocation was required. The City was highly responsive to the affected residents by providing sandbags and other resources to speed up cleanup and repairs. At the same time, above moderate17 https://healthyplacesindex.org/about/ 18 The same storm event also impacted the Moon Ridge neighborhood which is comprised of affordable housing for farmworkers south of the city limits.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 27 income neighborhoods were also affected by localized flooding and had to pump water and protect low portions of properties with sandbags.

The City of Half Moon Bay does not have any disadvantaged communities as defined under SB 535 as, “the top 25% scoring areas from CalEnviroScreen along with other areas with high amounts of pollution and low populations.”19
Disparities specific to the population living with a disability. Ten percent of the population in the City of Half Moon Bay are living with at least one disability, compared to 8% in the county. The most common disabilities in the city are ambulatory (4.8%), hearing (4.7%), and independent living (4.5%).

Disability
“Disability types include hearing difficulty, vision difficulty, cognitive difficulty, ambulatory difficulty, self-care difficulty, and independent living difficulty.” Source: California Department of Housing and Community Development Guidance, 2021, page 36.

For the population 65 and over, the share of the population with a disability increases. As mentioned above under access to transportation, San Mateo County is rapidly aging; therefore, this population with a disability—and accommodation and/or transportation needs—is likely to increase.

The data show few if any unemployment among residents living with a disability in Half Moon Bay, compared to 4% among residents without a disability. Countywide, the unemployment rate for residents with a disability is 4%, compared to 3% for residents without a disability (data at the city level has a large margin of error). Because 10% of the City’s residents have a disability, the City assumes that a number of these residents may wish to be employed, but have struggled to find suitable work and are not being included in unemployment data. The City has recently updated its Home Occupation Ordinance to facilitate cottage industries which are popular in Half Moon Bay. It is hoped that such businesses may be able to offer meaningful work to disabled residents. 19 https://oehha.ca.gov/calenviroscreen/sb535
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 28 Figure D-5: Access to Opportunity
SECTION IV. DISPROPORTIONATE HOUSING NEEDS
This section discusses disparate housing needs for protected classes including cost burden and severe cost burden, overcrowding, substandard housing conditions, homelessness, displacement, and other considerations.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 29 Disproportionate Housing Needs
“Disproportionate housing needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding, homelessness, and substandard housing conditions.”
Source: California Department of Housing and Community Development Guidance, 2021, page 39.

Housing needs. Since 2010, population growth in Half Moon Bay (10% increase) has kept pace with San Mateo County (8% increase) and the Bay Area as a whole (9%). Over the same period (2010 to 2020), the number of homes in Half Moon Bay increased 7.6%, which exceeded the growth rate for the county and largely kept up with the city’s population growth.

The Housing Needs Data Report for the City of Half Moon Bay highlights housing price diversity in the city noting that a “diversity of homes at all income levels creates opportunities for all Half Moon Bay residents to live and thrive in the community.” 20 The ownership housing stock in Half Moon Bay is similar to the county overall but does have a slightly higher share of units valued below $500,000 (mostly mobile homes, many in a senior living community) and fewer units valued over $1.5 million. Price increases have been severe throughout the county since 2011 and trends in Half Moon Bay over that period mirrored that of San Mateo County.

Rents have increased at a slower pace compared to the for sale market in San Mateo County even after accounting for more rapid increases in median rents from 2017 to 2019. However, in Half Moon Bay, median rent actually declined over the past three years—most likely due to the influx of income restricted rental units (see discussion of permit data above). The rental distribution in Half Moon Bay reflects a more affordable rental market than San Mateo County overall—32% of units rent for under $1,000 in the city compared to just 7% in the county and 26% rent for more than $2,500 in the city compared to 38% in the county. 20 Housing Needs Data Report: Half Moon Bay, ABAG/MTC Staff and Baird + Driskell Community Planning, 2021.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 30 The variety of housing types available in the city in 2020 are predominately single-family (60%) and single-family attached (12%). Though multifamily units increased faster than single-family between 2010 and 2020, the total share of multifamily is still below that of other jurisdictions, reflecting just 16% of the total housing stock.21 Cost burden and severe cost burden. Nearly one-third of all renter households in Half Moon Bay are cost burdened—spending more than 30% of their gross income on housing costs—and 14% are extremely cost burdened—spending more than 50% of their gross income on housing costs. Cost-burdened households have less money to spend on other essentials like groceries, transportation, education, healthcare, and childcare. Extremely cost-burdened households are considered at risk for homelessness. Rates of cost burden and severe cost burden in Half Moon Bay are slightly lower than in the county overall.

In Half Moon Bay, consistent with the county and region, lower-income households are more likely to experience housing cost burden. Two out of every three households earning less than 30% AMI—considered extremely low-income households—are severely cost-burdened, compared to only 7% of households earning 81% to 100% AMI and 0% of households earning more than 100% of AMI.

There are also disparities in housing cost burden in Half Moon Bay by race and ethnicity and family size. “Other/Multiple race” households (90% cost-burdened) and Hispanic households (57%) experience the highest rates of cost burden in the city. Asian households (21% cost-burdened), and non-Hispanic White households (24%) experience the lowest cost burden.

Large family households—considered households with five or more persons—experience cost burden at a rate of 52% compared to all other households at 31%. Cost-burdened renter households are more prevalent in the northern portion of the city while cost-burdened owners are dispersed throughout the city.

Voucher usage. Respondents to the resident survey who have searched for housing with vouchers (fewer than 10 people) report that finding a landlord that accepts vouchers is very challenging, mostly because the voucher is not enough to cover the market rent.

Overcrowding. The vast majority of households (95%) in Half Moon Bay are not overcrowded—indicated by more than one occupant per room. However, renter households are more likely to be overcrowded with 14% of households with more than one occupant per room compared to 2% of owner households.
21 Housing Needs Data Report: Half Moon Bay, ABAG/MTC Staff and Baird + Driskell Community Planning, 2021.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 31 Racial and ethnic minorities are more likely than non-Hispanic White households to experience overcrowding. Other races (27% overcrowded) and Hispanic households (28%) experience the highest rates of overcrowding. Low- and moderate-income households are also more likely to be overcrowded.

Geographically, overcrowded households are most present in the central part of the city, with 12 to 15% of households living in overcrowded conditions. This area also has the lowest share of residents of Hispanic descent, the highest median income, and the lowest poverty (2%) compared to other areas of the city.

Substandard housing. Data on housing conditions are very limited, with the most consistent data available across jurisdictions found in the American Community Survey (ACS)—which captures units in substandard condition as self-reported in Census surveys. In the City of Half Moon Bay, a low share of households are lacking kitchens or plumbing. Of renters, 1.1% are lacking kitchen facilities (and no households are lacking plumbing). The ACS does not report any owners in Half Moon Bay lacking either kitchen or plumbing facilities.

Some households are not living in substandard housing per se, but their housing situation is comprised of other condition challenges, including lack of accessibility modifications. In the resident survey conducted to support this AFFH assessment, residents were asked about the condition improvements they needed. Half Moon Bay residents with disabilities report needing grab bars in bathrooms (29%).

Homelessness. In 2019, 1,512 people were experiencing homelessness in the county during the One-Day Count, with 40% of people in emergency or transitional shelters while the remaining 60% were unsheltered. The majority of unsheltered people experiencing homelessness were in households without children. The majority of people in transitional housing were in households with children.

People who identify as American Indian or Alaskan Native (6% of the homeless population compared to less than 1% of the total population), Black (13%, 2%), White (67%, 51%), and Hispanic (38%, 28%) are overrepresented in the homeless population compared to their share of the general population. People struggling with chronic substance abuse (112 people), severe mental illness (305), and domestic violence (127) represented a substantial share of the homeless population in 2019.

Displacement. Owner households generally experience a greater amount of housing stability whereas renter households are more mobile (i.e., move more frequently). In the county as a whole, 8% of income assisted rental units are at high or very high risk for displacement, a total of 417 out of 5,264 total units in the county. In Half Moon Bay, there are a total of 371 income assisted rental units but all are at low risk of displacement. 468
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 32 Displacement Sensitive Communities
“According to the Urban Displacement Project, communities were designated sensitive if they met the following criteria:
 They currently have populations vulnerable to displacement in the event of increased redevelopment and drastic shifts in housing cost. Vulnerability is defined as:
 Share of very low-income residents is above 20%, 2017 AND
 The tract meets two of the following criteria:
− Share of renters is above 40%, 2017
− Share of people of color is above 50%, 2017
− Share of very low-income households (50% AMI or below) that are severely rent burdened households is above the county median, 2017 − They or areas in close proximity have been experiencing displacement pressures. Displacement pressure is defined as:
• Percent change in rent above county median for rent
increases, 2012-2017
OR
 Difference between tract median rent and median rent for surrounding tracts above median for all tracts in county (rent gap), 2017”
Source: https://www.sensitivecommunities.org/
No census tracts in Half Moon Bay are considered vulnerable to displacement based on the UCB Urban Displacement Project definition (above). Also, HCD does not identify any disadvantaged communities in Half Moon Bay or its immediate surrounding areas.

That said, the city acknowledges that there is displacement risk in the city due to the limited supply of housing overall and the high cost of housing, especially for minimum or low wage workers. This vulnerability was reflected in community input during the element update and is evidenced in the rental survey conducted for this AFFH:
• 31% of Half Moon Bay residents (16 of 51 survey respondents for this question) said they had been displaced in the past 5 years. This proportion was higher than the 469
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 33 majority of jurisdictions in the region and the county (21%) and closest to the displacement experienced in East Palo Alto (32%) and the City of San Mateo (37%). • The primary reason for displacement in Half Moon Bay was the landlord selling the unit. 31% of residents who had been displaced said this was the reason. This is much higher than in the county overall (18%).
• The second most common reason was the landlord wanting to move back into the unit (25%). This was higher than most other jurisdictions, except for Hillsborough (33%).
• Of those residents who had been displaced and have children, 58% said their children changed schools. The experience of those children was mixed, with some having more challenging environments and fewer activities and changes in perceived safety are equally split.

The City is also especially mindful of displacement risk due to environmental hazards.

Flooding and wildland fires in San Mateo County have already resulted in temporary displacement on the coast. An additional serious risk came to light after a tragic shooting took place on two farms within and adjacent to the city limits revealed unsafe living conditions for 19 farmworker households. The households included individuals, couples, and families. The City and San Mateo County collaborated and worked with service agencies to provide housing for every individual and family while longer-term replacement housing can be planned. However, due to this discovery, San Mateo County established a Farm Labor Housing Safety Task Force which is inspecting housing on all agriculture sites in the County.

This effort intends to identify needs and help resolve unsafe conditions. However, relocation may be required if resident safety can’t be assured.

Access to mortgage loans. Disparities by race and ethnicity are prevalent for home mortgage applications, particularly in denial rates. Hispanic (36% denial rate) and American Indian or Alaska Native households (50%) had the highest denial rates for mortgage loan applications in 2018 and 2019. Conversely, non-Hispanic Asian (23%) and White households (21%) have the lowest denial rates during the same time.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix D – Fair Housing Assessment Page | D - 34 Figure D-6: Disproportionate Housing Needs
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 1 Technical Report Appendix E: Community Engagement

OVERVIEW
The Housing Element is a significant document that will shape the future of our community.

Therefore, the Housing Element must reflect the vision of our local community who make the City of Half Moon Bay a special place to live, work and visit. To accomplish this, Half Moon Bay developed a broad and diverse outreach plan designed to reach as many community members as possible. For some of the outreach, the City partnered with other San Mateo county jurisdictions via 21 Elements, in a joint countywide outreach effort. 21 Elements is a multi-year, multi-phase collaboration of all twenty-one San Mateo County jurisdictions, along with partner agencies and stakeholder organizations. The project aims to support jurisdictions in developing, adopting, and implementing local housing policies and programs. It is a forum for sharing resources, successful strategies, and best practices. The City also conducted its own numerous outreach and engagement sessions focused on City and Coastside residents, employees, and service providers. The approaches to education and engagement included:

Website and Social Media: 21 Elements participated in and helped shape the “Let’s Talk Housing” outreach program to increase awareness and participation in the Housing Element Update process.

This program included a website and used various social media platforms, interlinked with the City’s website and social media.

Community Meetings: Many community members participated in a range of sessions including City Council and Planning Commission meetings, focus groups, and stakeholder interviews. The City also participated in several meetings and webinars in partnership with 21 Elements.

Outreach Activities: 21 Elements established an Equity Advisory Group to ensure outreach was set up to meet people where they were at, as much as possible. City staff supported this effort.

Our Stories: To learn more about the housing experiences of people in the County, 21 Elements asked community members to share their stories to include as many voices as possible in the Housing Element. Experiences were shared by a diversity of residents, including small families, seniors on fixed incomes, educators, people with disabilities, and single parents.

It is more important than ever to include as many voices as possible in the Housing Element. Housing Elements at their best can provide an opportunity for everyone to add their voice to the conversation. However, many people are too often left out of the process. Renters, workers, young families, youth, people of color, immigrants, refugees, non-English speakers, and people with disabilities are often unable to participate in outreach activities when scheduled, don’t know how to get involved, or don’t trust the process. The City’s goal, assisted by 21 Elements, was to change that. Specifically, the City:
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 2  Ensured foreign language translation and interpretation were included in meetings and materials.
 Formed an Equity Advisory Group consisting of 18 organizations across San Mateo County that provided feedback on outreach and materials, and shared information about the Housing Element Update and how to participate in the process with the communities they serve.
 Held meetings in partnership with community organizations.  Developed an Affirmatively Furthering Fair Housing survey.

As a whole, the approach brought forward a diversity of voices and perspectives. While the City Council routinely hears from diverse voices about housing and service needs during Council public forums and other sessions; the Planning Commission typically does not. Thus, this process provides a critical touchpoint for the City’s primary land use policy review body. To that end, a draft of this summary was presented to the Planning Commission in July 2022 and the City started to offer Spanish translation and interpretation at every Planning Commission meeting. The hope is to help the community feel more comfortable in that setting and that the Commission will be especially sensitive to community needs having participated in and reviewed the community outreach for the Cycle 6 Housing Element.

MULTI-FACETED COMMUNITY ENGAGEMENT
The City developed a diverse outreach plan to hear from as many community members as possible.

This section includes a detailed summary of both the regional engagement efforts supported by 21 Elements as well as City-specific engagement efforts. Further information from City meetings, interviews, and focus group sessions can be found in the Housing Element References.

Website and Social Media
As a starting point for accomplishing extensive outreach, the City developed a clear online presence with all the information needed to understand the update process and know how to participate.

City of Half Moon Bay 2023-2031 Housing Element Update Webpage A 2023-2031 Housing Element Update Webpage (https://www.half-moon-bay.ca.us/775/HousingElement-Update-2023-2031) was developed as a part of the City website with the intent of being an online resource for the community. It offered educational FAQs, project updates, meeting details, and documentation for review. The project website made it easy for people to participate by providing meeting details and the opportunity to sign up for email updates. Links to public meetings were provided and directed viewers to agendas, minutes, and videos of the meetings (if recorded).

The City also established a Housing Element email list and as of July 2022, 450 recipients had signed up to receive updates about the Housing Element.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 3 Figure E-1: 2023-2031 Housing Element Update Webpage
Let’s Talk Housing Website
To reach a broader audience and supplement the City of Half Moon Bay 2023-2031 Housing Element Update Webpage, the City promoted 21 Elements Let’s Talk Housing website in March 2021. The website was established to clearly explain what a housing element is, why it matters, and how to get involved. It was made available in Arabic, Chinese, English, Spanish, and Tagalog, designed to be responsive on all types of devices, and included accessibility features. The website had been viewed more than 17,000 times, with more than 20 percent occurring from mobile devices by February 2022. Let’s Talk Housing Facebook, Instagram, Twitter, and YouTube accounts were also created and maintained to keep people informed about upcoming or past events.

Informational Videos on the Housing Element Update
After completing a series of introductory meetings on the Housing Element Update (see below), 21 Elements developed shorter 4-minute snippets to ensure information was more accessible and less onerous than watching an hour-long meeting. Two videos were produced – What is a Housing Element and How it Works and Countywide Trends and Why Housing Elements Matter – in Arabic, Chinese, English, Spanish, and Tagalog. The videos were made available on the Let’s Talk Housing YouTube channel and website and shared on social media.

City of Half Moon Bay’s Social Media
The City utilized multiple social media channels such as NextDoor, Twitter, Instagram, and Facebook to promote specific Half Moon Bay public meetings and hearings related to the Housing Element Update.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 4 Public Meetings and Hearings
The City of Half Moon Bay held and participated in a variety of in-person and virtual meetings to inform the public about the Housing Element and hear what matters to the community.

Introductory Meeting to the Housing Element Update
The City of Half Moon Bay helped develop and facilitate a 90-minute virtual countywide meeting about the Housing Element update. The meeting was held on April 14, 2021, and provided community members with an introduction to the Housing Element update, why it matters, information on the Let’s Talk Housing outreach effort, and countywide trends. City staff then facilitated a breakout room discussion with community members on housing needs, concerns, and opportunities, and answered any questions. A poll was given during the meeting, to identify who was joining us and more importantly who was missing from the conversation, including if they rent or own, who they live with, their age, and ethnicity. Time for questions was allotted throughout, and meeting surveys were provided to all participants after the meeting along with all discussed resources and links.

The April 14th meeting included Half Moon Bay along with Atherton, Daly City, Pacifica, Woodside, and Unincorporated San Mateo County. Forty-six people registered for the meeting, including nine participants connected to Half Moon Bay. Of these, seven reported that they live in HMB, while two said they were present because they were interested in housing issues in our community. Of the nine people, two-thirds own their home while the remaining third rent. Two-thirds have lived in HMB for over 21 years. Demographically, four of the participants were over 70, three of them between 50 and 69, and two between 30 and 49. Eight out of nine identified as White.

At the start of the meeting, participants were asked to share a word in the chat describing housing now, and the housing they envisioned in their communities ten years from now. The resulting “word clouds” are shown below.

Now In 2030
The majority of the meeting was spent in jurisdiction-specific breakout sessions, which started with a presentation from the city team. That presentation included an overview of important groundwork that would support and inform the housing element update, including the update to the city's land use plan map, currently under review by the Coastal Commission. This includes land use changes in the Town Center, creation of a Workforce Housing Overlay, and upzoning. Many questions focused 475
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 5 on constraints that make it difficult and expensive to build new housing and ADUs, and on how the City can help ensure affordable units for lower-income families. Community members expressed appreciation for the outreach and opportunity to learn and give input, and shared ideas about how to ensure broad participation in the update effort.

All About RHNA Webinar
City staff joined a webinar with 21 Elements in April 2021 to provide information and answer community questions about the RHNA process. 264 people registered and 80 questions were answered over three hours. The recording of this meeting and the FAQ can be found here.

City Council Listening Sessions
Each year the Half Moon Bay City Council hosts listening sessions to hear directly from the people who live and work in Half Moon Bay to encourage a broad range of the community’s input regarding the City’s critical priorities. The City Council uses this input as a foundation for annual priority setting and budgeting. For several years leading up to drafting the Cycle 6 Housing Element, affordable housing has emerged as and remained a top community and City priority. Community input received from the Listening Session includes current information about housing needs and policy recommendations directly relevant to the Housing Element. The most recent two years of input, received over four separate sessions, conducted via Zoom with simultaneous Spanish translation, is summarized as follows:

City Council Listening Session #1
On March 3, 2021, the City Council held its annual listening session series. In this annual series, however, the community was informed about the City’s need to update the Housing Element. About 18 community members attended and expressed the need for housing for all ages and stages of life that is affordable and available in the city. Rental assistance and housing support were encouraged to improve quality of life and to support the residents in the community. Direct outreach to the unhoused community was said to be a pressing need, and that those experiencing homelessness should receive more information about the Coast House emergency shelter, how to get in, and how to qualify for a room.

City Council Listening Session #2
On March 6, 2021, the City Council held its second listening session with 10 community members in attendance. Community members shared their appreciation to the City for the affordable housing already located in the community. To help meet the RHNA, attendees suggested and were in favor of accessory dwelling units (ADUs) to help provide more affordable housing options. Some mentioned that they would like to see the City provide opportunities to house refugees.

City Council Listening Session #3
On March 9, 2021, the City Council held its third listening session with 30 community members in attendance. Affordable housing and farmworker housing were highlighted as a focus for the housing element update. Local business owners also advocated for the need for affordable housing for staff and essential workers. Attendees suggested that the City ask workers about their housing 476
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 6 preferences concerning location and type. Overcrowding was mentioned to be a growing concern, especially for kids who need good quality housing. Gratitude to the City was shared for pro-actively listening. Nonetheless, community members urged that the City not stop its efforts and continue to keep affordable housing and farmworker housing a priority. Some attendees wondered if it is feasible to plan for small rural housing and in-town housing, or if one had to be attended to at a single time.

City Council Listening Session #4
On March 13, 2021, the City Council held its last listening session with 22 community members in attendance. Attendees stressed the importance of keeping affordable housing at the top of the priority list. In addition to affordable housing is the need for rental assistance to ensure residents do not become unhoused. Some participants encouraged the City to broaden its scope to consider already developed properties that may be underutilized, especially in the downtown area.

City Council and Planning Commission Work Session – Sites, Opportunities, and Constraints On November 9, 2021, the City Council and Planning Commission hosted a special joint work session on the Housing Element. The meeting was conducted via Zoom with simultaneous Spanish translation throughout. The agenda included a presentation of several broad categories of affordable housing types previously identified by the community as most-needed (e.g., farmworker housing, mobile homes, multi-generational family housing, and infill housing in the resource-rich Town Center area). Detailed information about specific sites intended for inclusion in the 6th Cycle Housing Element included sites owned by the City, Cabrillo Unified School District (CUSD), churches, agricultural, and other property owners. For each, the presentation covered opportunities, constraints, and potential City actions to be taken to further support development with affordable housing. The session was well-attended with 83 individuals, including 25 who spoke during the public forum.

Stakeholder Listening Session Series
City staff joined 21 Elements for a facilitated series of listening sessions held between September and November 2021 to hear from various stakeholders who operate countywide or across multiple jurisdictions. The four sessions convened more than 30 groups including fair housing organizations, housing advocates, builders/developers (affordable and market-rate), and service providers, to provide observations on housing needs and input for policy consideration. Summaries for each session can be found here. Key themes and stakeholder groups included:

Fair Housing: Concern for the end of the eviction moratorium, the importance of transit-oriented affordable housing and anti-displacement policies, and the need for education around accessibility regulations and tenant protections. 8 stakeholder groups provided this feedback, including the following:
 Center for Independence www.cidsanmateo.org
 Community Legal Services of East Palo Alto (CLSEPA) www.clsepa.org  Housing Equality Law Project www.housingequality.org
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 7  Legal Aid for San Mateo County www.legalaidsmc.org
 Project Sentinel www.housing.org
 Housing Choices www.housingchoices.org
 Public Interest Law Project www.pilpca.org
 Root Policy Research www.rootpolicy.com
Housing Advocates: Concern for rent increases and the need for ongoing outreach to underserved and diverse communities, workforce housing, deeply affordable and dense infill, and tenant protections for the most vulnerable. 6 stakeholder groups provided this feedback, including the following:
 Housing Leadership Council www.hlcsmc.org
 Faith in Action www.faithinactionba.org
 Greenbelt Alliance www.greenbelt.org
 San Mateo County Central Labor Council www.sanmateolaborcouncil.org  Peninsula for Everyone www.peninsulaforeveryone.org
 San Mateo County Association of Realtors www.samcar.org Builders and Developers: Local funding, tax credit availability, and concern that appropriate sites limit affordable housing while sites, construction costs, and city processes limit market-rate housing. 12 stakeholder groups provided this feedback, including the following:
 Affirmed Housing (Affordable) www.affirmedhousing.com  BRIDGE Housing (Affordable) www.bridgehousing.com
 The Core Companies (Affordable, Market Rate) www.thecorecompanies.com  Eden Housing (Affordable) www.edenhousing.org
 Greystar (Market Rate) www.greystar.com
 Habitat for Humanity (Affordable) www.habitatsf.org
 HIP Housing (Affordable) www.hiphousing.org
 Mercy Housing (Affordable) www.mercyhousing.org
 MidPen Housing (Affordable) www.midpen-housing.org
 Sand Hill Property Company (Affordable, Market Rate) www.shpco.com  Sares | Regis (Market Rate) www.srgnc.com
 Summerhill Apartment Communities (Market Rate) www.shapartments.com Service Providers: More affordable housing and vouchers or subsidies for market-rate housing are needed, along with on-site services and housing near transit, and jurisdictions should work with providers and people experiencing issues before creating programs. 10 stakeholder groups provided this feedback, including the following:
 Abode Services www.adobeservices.org
 Daly City Partnership www.dcpartnership.org
 El Concilio www.el-concillio.com
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 8  HIP Housing www.hiphousing.org
 LifeMoves www.lifemoves.org
 Mental Health Association of San Mateo County www.mhasmc.org  National Alliance on Mental Illness www.namisanmateo.org  Ombudsman of San Mateo County www.ossmc.org
 Samaritan House San Mateo www.samaritanhousesanmateo.org  Youth Leadership Institute www.yil.org
Other Outreach Activities
The City set out to collect as much feedback as possible from the community, from general concerns and ideas as to where new housing could go. It was also important to the City to consider community outreach best practices and partner with organizations working in the community, to ensure as many people as possible are reached and done so thoughtfully.

City of Half Moon Bay Stakeholder and Service Providers Interviews In April 2022, City staff invited affordable housing providers and service agencies for interview sessions to gain a better understanding of the housing needs, challenges, and desires of the specific populations they serve. Agencies were identified as those who are especially focused on supporting the San Mateo coastside, or those that have identified themselves to staff as seeking to increase their presence on the coast. Of the stakeholders invited, ten agencies participated. Interviews were unstructured and casual to allow each agency to organically discuss issues and present recommendations. The input received was specific to the Housing Element policy development and site selection process.

Coastside Hope
On April 12, 2022, City staff met with the Executive Director of Coastside Hope, an organization that provides support to clients and their families who live and work on the Coastside and are seeking permanent residency. The discussion highlighted the need for more affordable housing, but especially for farmworkers and greenhouse workers. The Executive Director stressed that affordable rental housing developments should be combined with other programs to help households save money to buy a home. Tenant education and protection were mentioned as a key tool for reducing discrimination and inequitable practices.

A “community first” approach was suggested for the City to ensure that housing is built and secured for residents before interested parties move in. Funding service agencies in the City help support residents stay in their homes but they need to be more flexible as master leaseholders may not wait long for their payment.

Senior Coastsiders
On April 12, City staff met with the Executive Director of Senior Coastsiders to discuss what the organization may require support with, any housing issues their clients have been experiencing, and 479
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 9 the current housing support programs. Like many other organizations, Senior Coastsiders supports accessory dwelling units to help increase the production of affordable units.

Abundant Grace
On April 14, 2022, City staff met with the Executive Director and their staff at City Hall. Abundant Grace is an organization that serves the homeless and low-income communities of Half Moon Bay.

They discussed coastside needs such as addressing the lack of housing available for residents with housing vouchers. Farmworkers’ needs are a major concern because their income cannot keep up with the increased cost of living.

Housing Choices
On April 14, 2022, City staff met with the Executive Director and Senior Housing Advocate of Housing Choices, an organization that provides housing navigation services to people with developmental and other disabilities. In addition to discussing their clients’ needs and desires for housing, they shared specific policy recommendations for Half Moon Bay, presented at the end of this report.

Housing Leadership Council (HLC)
On April 14, 2022, City staff met with the Policy Manager at the Housing Leadership Council of San Mateo County. HLC is a membership organization that works with its partners to preserve and expand the range and supply of adequate, accessible, and affordable housing for residents and workers of San Mateo County. The Council ensures everyone who works, lives, or grows up in San Mateo County can obtain a suitable home. During the interview, they shared a few things they would like to see for the future of housing in Half Moon Bay. This includes an analysis of the Cycle 5 Housing Element to determine why the City has not met its housing needs as a means to help ensure that the upcoming housing element is holistic and realistic for housing production. HLC shared best practices on their Housing Element Policy Platform, included in the Detailed Input section at the end of this technical report.

MidPen Housing
On April 14, 2022, City staff met with the Vice President of Business Development at MidPen Housing, one of the largest, most trusted nonprofit developers, owners, and managers of highquality affordable housing in Northern California. In advance of the interview, MidPen Housing provided its “Housing Element Best Practices: Lessons from Previous Cycles”. The interview covered their recommendations, including a discussion of their applicability to the City of Half Moon Bay included in the Detailed Input section at the end of this technical report.

Society of St. Vincent de Paul
On April 14, 2022, City staff met with the Executive Director, Director of Engagement and the Lead Case Manager at the Society of St. Vincent de Paul, who provides person-to-person services of time, talent, and resources to help neighbors in need. Their main goal is to help people get housed. As more families need support, they will continue to support and refer people to services that can directly impact them in the City since they are primarily based in San Mateo. 480
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 10 Boys and Girls Club
On April 19, 2022, the City met with the Coastside Executive Director of the local Boys and Girls Club.

The main issue mentioned was centered around affordability and availability of housing for their staff and clients. Their younger staff cannot afford to move out of their family homes because there are no available and affordable homes for them. This leads to overcrowding in the City which is a growing concern.

As a trusted partner in the Community, the Boys and Girls Club offered to help share outreach materials and information.

HIP Housing
On April 19, 2022, City staff met with the Director of Programs at HIP Housing, a local nonprofit organization that has provided housing and Home Sharing Services in San Mateo County. In the interview, they shared more about their organization and a desire for more support with outreach in Half Moon Bay and potentially working with HIP to increase ADU affordability. As they increase their presence on the Coast, they are working on strategies to make home sharing units count toward RHNA.

Habitat for Humanity
On April 19, 2022, City staff met with the Chief Executive Officer at Habitat for Humanity, an organization that builds homes and sustains affordable homeownership opportunities for families.

They shared that the City has a unique opportunity to take some of the potential sites and think differently about types of housing and partnerships. This includes the consideration of ownership opportunities as part of an affordable housing development. Additionally, they shared many creative recommendations for the City to consider as potential opportunities.

Focus Groups
The City hosted two focus groups in June 2022 to provide a small and intimate platform for some of the City’s most vulnerable communities, including seniors and Latino residents. The City’s intent for these focus groups was to gain a better understanding of their specific housing needs and obtain feedback on how the City can best support them in the years to come.

Senior Coastsiders Focus Group
On June 8, 2022, the project team met with 8 community members connected to Senior Coastsiders.

The purpose of this focus group was for participants to provide input about housing development and policy with a focus on senior needs. Participants shared that Half Moon Bay is a wonderful and friendly community. Priorities for housing include shared housing, controlled rent increases, and support for older adults including financial assistance for home maintenance. Common areas of concern include homelessness, the vulnerability of certain household types such as female-headed households, and the need for housing for people with disabilities. 481
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 11 Ayudando Latinos A Soñar (ALAS) Focus Group
On June 16, 2022, City staff held an in-person focus group in the backyard of ALAS’ main office. The purpose of this focus group was for participants to provide input about housing development and policy with a focus on the needs of their community. It was facilitated by City staff and conducted in Spanish. Those in attendance represented low-income Latino families and farmworkers. In total, 8 adults participated, as well as several grade and middle school-aged children. Participants shared that they enjoy Half Moon Bay as a safe, beautiful small town that is close to their families and friends. They identified priorities for housing, highlighting the needs of essential workers, including farmworkers. Common areas of concern included high rent, overcrowding, and impacts on health and childhood development.

Creating an Affordable Future Webinar Series
The City of Half Moon Bay and 21 Elements offered a 4-part countywide webinar series in the fall of 2021 to help educate community members about local housing issues. The sessions were advertised and offered in Cantonese, Mandarin, and Spanish, though participation in non-English channels was limited. All meetings and materials can be found here. The following topics, and how each intersects with regional housing challenges and opportunities, were explored:

Why Affordability Matters: Why housing affordability matters to public health, community fabric, and county residents, families, workers, and employers.

Housing and Racial Equity: Why and how our communities have become segregated by race, why it is a problem, and how it has become embedded in our policies and systems.

Housing in a Climate of Change: What is the connection between housing policy and climate change and a walk through the Housing & Climate Readiness Toolkit.

Putting it All Together for a Better Future: How design and planning for much-needed new infill housing can be an opportunity to address existing challenges in our communities.

The series included speaker presentations, audience Q&A, breakout sessions for connection, and debrief discussions. Participants were eager to discuss and learn more about housing challenges in their community. They asked questions and commented in the chat and shared their thoughts in a post-event survey. Overall, comments were mostly positive and in favor of more housing, though some were focused on the need for new affordable housing. There was a lot of interest in seeing more housing built (affordable housing), concern about change or impact on schools, parking, and quality of life, and personal struggles with finding housing that is affordable and accessible shared.

Some participants wanted more in-depth education and discussion of the next steps, while others had more basic questions they wanted answered.

In total, 754 registered for the series. Of those who shared, the majority identified as White (55%) or Asian (24%) and ranged between 30 and 70 years old. Over half have lived in the county for over 21 years and nearly two-thirds owned their homes. For more information, see the summary here. 482
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 12 Equity Advisory Group
In alignment with community outreach best practices, it was important to include the guidance of and foster partnerships with community organizations to help ensure everyone’s voices were heard during the Housing Element update. In response, an Equity Advisory Group (EAG) was formed consisting of 15 organizations or leaders across the county that are advancing equity and affordable housing. A stipend of $1,500 was originally provided for meeting four to five times over 12 months to advise on Housing Element outreach and help get the word out to the communities they work with.

After meeting twice in 2021, it was decided that the best use of the EAG moving forward would be to provide more focused support in 2022 based on jurisdiction needs and organization expertise. To date, EAG members have facilitated and hosted community meetings in partnership with 21 Elements, collected community housing stories to put a face to housing needs, advised on messaging, and amplified events and activities in their communities. The EAG continues to work collaboratively with jurisdictions and deepen partnerships, as well as connect community members to the Housing Element Update process. All participating organizations are featured on the Let’s Talk Housing website and include the following:
 Ayudando Latinos A Soñar (ALAS) www.alashmb.org
 Community Legal Services www.clsepa.org
 El Comite de Vecinos del Lado Oeste (El Comite) www.tenantstogether.org/resources/elcomité-de-vecinos-del-lado-oeste-east-palo-alto  EPACANDO www.epacando.org
 Faith in Action www.faithinaction.org/federation/faith-in-action-bay-area/  Housing Choices www.housingchoices.org
 Housing Leadership Council www.hlcsmc.org
 Menlo Together www.menlotogether.org
 Nuestra Casa www.nuestracasa.org
 One San Mateo www.onesanmateo.org
 Peninsula for Everyone www.peninsulaforeveryone.org
 Puente de la Costa Sur www.mypuente.org
 San Mateo County Health www.gethealthysmc.org
 Youth Leadership Institute www.yli.org/region/san-mateo  Youth United for Community Action www.youthunited.net Affirmatively Furthering Fair Housing Survey
A total of 63 residents from Half Moon Bay participated in the 21 Elements AFFH survey. Participants from Half Moon Bay shared a great need for assistance in taking care of themselves or their homes and were more likely to have trouble keeping up with expenses, such as property taxes. Access to public transit, improved street crossings, and the need for more sidewalks were shared concerns.

Residents also expressed that they need help finding housing. The full survey summary can be found here, and is also discussed in the AFFH chapter of the housing element. 483
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 13

KEY TAKEWAYS
Key takeaways emerged throughout the outreach process. The first part focuses on the regional outreach efforts led by 21 Elements that took place in partnership with local cities, including Half Moon Bay. The status of regional housing has potential effects on the Half Moon Bay community due to the City’s proximity to jobs-rich areas and high population centers located within San Mateo County and the greater Bay Area. The second part consists of key takeaways that City staff gathered through specific outreach at public meetings and through targeted outreach efforts with community groups and stakeholders in Half Moon Bay. The City acknowledges that many concerns taking place on a regional level have similarities to concerns gathered from local outreach.

Countywide Key Takeaways Summary
Housing is personal: People often have differing views on housing because it is a very personal issue tied to feelings of safety, belonging, and identity. Often the comments reflected people’s current housing situation. Those with safe, stable housing that they can afford were more concerned with change. Those without were more interested in bolder policies and more housing generally. Many people shared meaningful stories of being priced out of their communities or of their children not being able to live in the community where they grew up. Click here for a sample story.

The price of housing is a major concern: Many voiced concerns about the high cost to rent or buy a home today, either for themselves, friends, or family. It is an issue that touches a lot of lives.

More housing is needed: Generally, people believe there is a need for more housing, particularly affordable housing. However, there are diverging views on how to accomplish this, where housing should go, and what it should look like.

Single-family neighborhoods are polarizing: While some people voiced their interest in up-zoning single-family neighborhoods or eliminating them altogether, other homeowners want to protect them and in turn, the investment they have made.

Affordable housing is a top concern: Many felt that more needed to be done to promote affordable housing. They also felt that developers should be eligible for incentives and opportunities that make them more competitive.

The process is too complicated: There was significant concern that the development process is too slow and there is too much uncertainty.

Better information resources: People wanted to know how to find affordable housing in their communities and navigate the process of applying for it. 484
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 14 Issues are connected: Transportation, climate change, access to living wage jobs, and education opportunities are all tied to housing and quality of life. These issues are not siloed in people’s lives and there is a desire to address them in interconnected ways.

Equity is on people’s minds: People want to talk about housing inequities and, even more so, discuss how to solve them. There was interest in ways to create new opportunities for housing and asset building for all that also address past exclusions.

Regional input matters but there’s more to figure out: It was valuable to build a broader sense of community and share resources at the countywide level. However, it was challenging to engage non-resident community members on jurisdiction-specific input.

Diversity in participation was a challenge: Despite partnering with organizations to engage with the hardest-to-reach communities and providing multilingual outreach, achieving diversity in participation was challenging. In the wake of Covid-19, organizations already operating on limited resources were focused on supporting immediate needs, while the added stresses of life coupled with the digital divide added additional barriers for many.

Half Moon Bay Key Takeaways Summary
Farmworkers cannot afford stable housing: Many farmworker households in Half Moon Bay earn below the Federal poverty line with incomes in the acutely low- and extremely low-income categories. As a result, farmworkers often live in substandard living conditions that can include shared beds and living areas. Farmworkers, many with families, are seeking more permanent housing; however, without enough affordable housing, this population is often forced to move amid unstable living arrangements and discriminatory housing practices.

Over-crowded housing: The City heard from multiple community members and stakeholders that many families are forced to live in overcrowded housing due to the cost of rent and inability to gain approval to move forward in the rental application process. In some situations, multiple families share a home or apartment designed for only one family to live in. Therefore, in many cases, children and parents share a single room without privacy and adequate sleeping arrangements. Some families shared how these types of living situations have a direct effect on their mental health as well as child development and education.

Illegal subleases and price gauging: Related to over-crowded housing, many households with limited resources are forced to enter into housing arrangements that are not governed by a lease agreement. Although free legal services are available, tenant rights are limited without clear documentation and proof of unfair practices. In some cases, existing tenants with a valid lease are subleasing rooms without landlord consent, at higher than market rate for a single room. This places some households at even higher risk of illegal housing practices such as multiple unlawful eviction practices, insufficient lease terms, and rent increases that lead to price gauging. 485
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 15 More affordable housing is needed in Half Moon Bay: Through the outreach process, there was a substantial amount of support for additional affordable housing to be built in Half Moon Bay. Many respondents stated affordable housing needs to be built as soon as possible and that the City of Half Moon Bay should approve policies that allow more affordable housing to be built immediately.

Teachers and essential workers cannot afford to stay: Many speakers stated teachers and essential workers are finding it increasingly difficult to remain housed in Half Moon Bay and surrounding communities due to the high cost of housing. The need for this population to pay affordable rent was commonly shared as a result of wages that have not been keeping up with the cost of living and inflation.

City housing funds and land contribution: Multiple stakeholder and service agency organizations stated the need for a variety of funding sources to develop affordable housing and provide programs that support the community. Affordable housing developers stated feasibility increases with zoning for medium- and high-density residential in addition to City provided land and/or other funding sources.

HOW THE COMMUNITY SHAPED THE HOUSING PLAN
The Half Moon Bay community and local service agencies shaped the Housing Plan. Numerous policies were updated or added to the Cycle 6 Housing Element to make it more actionable and sensitive to very special needs that have been identified since the Cycle 5 Element was in place.

There are 6 Housing Plan Goals under which policies and programs are present to achieve the goal.

The goals acknowledge the need for more affordable housing, preservation of existing housing, the need for diverse housing, the need for housing resources and tenant protections, the community’s commitment to sustainability, and the importance of effective Housing Plan implementation. The goals are as follows:

Goal 1 - Housing Production:

Facilitate development of high-quality and diverse types of housing for all income levels and household types.

Goal 2 – Housing Preservation:

Preserve and improve Half Moon Bay’s existing neighborhoods and housing supply.

Goal 3 – Housing Choices:

Expand housing choices for large and multi-generational households, the elderly, persons with developmental or other disabilities, farmworkers, female-headed households, unhoused individuals, and persons with special housing needs.

486
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 16 Goal 4 – Protections and Resources:

Promote housing opportunities and establish resources for all persons regardless of race, sex, age, marital status, ancestry, national origin, color, or sexual orientation.

Goal 5 – Housing Sustainability:

Support sustainability measures in new and existing residential development.

Goal 6 – Housing Plan Implementation:

Implement the Cycle 6 Housing Plan using annual reports, monitoring, periodic ordinance updates, and other means to maintain plan effectiveness throughout the planning period.

The following table provides a “crosswalk” between Housing Element programs with the Key Takeaways from what the City learned from the Half Moon Bay-specific community engagement.

Table E-1: Key Takeaway and Housing Programs
Key Takeways Highlights of Responsive Housing Plan Programs More Affordable Housing:
• Farmworkers
• Other Essential Workers
• Special Needs Populations
Program 3-4: Housing for Essential Workers emphasizes use of the Workforce Housing Overlay to enable affordable housing development for farmworkers and other essential workers.

Program 3-1: Senior and Disable Housing prioritizes affordable housing developments for seniors, persons with development and other disabilities, and other special needs populations.

Improve the Development
Process
Program 4-9: Reduce Affordable Housing Development Costs targets reductions in development impact fees for affordable housing.

Provide Better Information Program 4-3: Multilingual Housing Information Access specifies a suite of approaches for providing access to information for tenants and households seeking housing.

Support Renters and Improve
Conditions:
• Tenant Rights
• Crowding
Program 4-5: Tenant Relocation Assistance Ordinance will require landlords with serious building code violations resulting in unsafe living conditions to provide at least three months of rent to tenants who need to relocate.

Programs 3-3: Home Share and Cooperative Housing and 3-5: Large and Multi-Generation Households outline diverse and flexible housing types and living arrangements for large families and households to reduce crowding.
487
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 17 Key Takeways Highlights of Responsive Housing Plan Programs Funding:
• More is needed
• Spend it well
Program 4-6: Increased Funding for Affordable Housing identifies potential funding sources for the City’s Affordable Housing Fund as well as partnerships with other resources.

Program 4-7: Affordable Housing Fund Management and Use is based on the City’s Affordable Housing Fund Allocation Guidelines which prioritize funding for new and deeply affordable units as well as for preserving existing affordable units.

Use Public Land for Housing Program 4-8: Use Public and Quasi-Public Owned Lands for Affordable Housing emphasizes use of the Workforce Housing Overlay on sites owned by the City, School District, and religious institutions for affordable housing development.

PUBLIC INPUT AND REVISIONS TO THE FIRST PUBLIC DRAFT HOUSING ELEMENT The First Public Draft Housing Element was made available for a 30-day public comment period running from April 17 - May 16, 2023. The Element was provided on the City’s website as a combined and searchable PDF file, as well as by individual section. Hard copies of the Element were available at the Half Moon Bay Library and City Hall. Announcements about the Housing Element’s availability and comment period were broadly circulated as follows:
• City eNewsletters Notifications: 8,884 email addresses • City social media (Twitter, Facebook, and Instagram): 14,015 following • Housing Element website
• Announcements at public meetings
To further ensure that interested parties had an opportunity to learn about the Housing Element and provide comments, the City held a Work Session on May 9, 2023. The session started at 6:00 PM with a one-hour reception for community members to discuss the Housing Element with each other and City staff. Display boards presented the Housing Element’s Goals, Housing Opportunity Sites, and RHNA. The Work Session was held jointly by the City Council and Planning Commission and commenced at 7:00 PM. The session was offered in a hybrid format and also televised. The public comment period was open for in-person and Zoom attendees. The City also set up a Housing Element email to facilitate the submittal of written comments.

Summary of Input on the First Public Draft Housing Element Written Comments: Twenty-one written comments were submitted on the First Public Draft Housing Element. Table E-2 provides an index and summary of the main themes of each written comment. The full text of each written communication is provided at the end of this Technical Report.
488
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 18 Public Comments from May 9, 2023, Work Session: Fourteen speakers addressed the City Council and Planning Commission at the Work Session held on May 9, 2023. Table E-3 provides an index and summary of the main themes of each speaker’s comments. Detailed meeting summary notes are provided at the end of this Technical Report. The summary includes additional summary notes of each speaker’s comments as well as a summary of the City Council and Planning Commission’s discussion and direction. Two Planning Commissioners also submitted written comments and questions in advance of the work session, and these are also provided at the end of the summary.

Broadly, public comments could be sorted into three categories. The categories are color coded to help illustrate the primary areas of interest in Tables E-2 and E-3 as follows:

Diverse Affordable Housing: for older adults and families; consider mobile homes Stone Pine Road Housing Opportunity Site
Infrastructure/Parking
Table E-2: Written Comment Index/Summary
# Commenter Comment Topic(s)
1 Michelle Lutke Seniors are at risk for displacement; had to leave HMB due to a lack of moderate-income housing.
2 Sylvia Teng Need to address coastside traffic/infrastructure needs (e.g., more traffic signals) before adding more housing.
3 Steve Hyman Concerned about traffic and location of farmworker housing for 555 Kelly Avenue and 880 Stone Pine Road; the farmworker housing should be on the farms, not Downtown.
4 Dave Powell Senior housing options for low- and moderate-income households need to be better addressed.
5 Peter Kroosz Concerned about 880 Stone Pine Road housing site access and traffic.
6 Linda Goldstein Supports housing justice; the City should develop safe and equitable housing.
7 Marcy Barton Questions about the Pilarcitos trail extension and relationship to the 880 Stone Pine Road housing site.
8 Bill Heavlin Lower-income units not produced during Cycle 5; need more for Cycle 6 and suggested development incentive program.
9 Kathryn Murdock Stone Pine Road housing site is suitable for mixed occupancy; concerned about concentrating affordable housing on this site. 10 Joanne Rokosky Need more than 480 units per RHNA; teacher housing is vital; assistance for sublease/renters and price gouging is needed. 11 KC Branscomb Shared a variety of policy and program observations related to farmworker housing on Rural Coastal designated properties:

ADUs, WHO, trailer residences, and high pre-development costs. 489
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 19 # Commenter Comment Topic(s)
12 Kirsten Loegering Concerned about traffic and impacts of Stone Pine Road housing site on the Cypress Cove neighborhood.
13 Caeli Collins Asked questions about encouraging farmworker housing; development standards to promote building such housing
including ADUs; and efforts to protect agricultural land use in general.
14 Sandy Miranda Concerned about Stone Pine Road housing site; supports HWY 92 access.
15 Rob Robinett Opposes Stone Pine Road housing site; supports HWY 92 access. 16 Carole Black Concerned about opportunity sites, most notably 880 Stone Pine Road for traffic and the need to add WHO; interested in mixedincome opportunities. 17 Alexandru Chitea “Vote” against the Stone Pine Road housing site. 18 Mark Gammon Concerned about the 880 Stone Pine Road housing site. 19 Keet Nerhan Concerned about Housing Element’s effectiveness in addressing constraints to meeting RHNA.
20 Sha T Concerned about Stone Pine Road traffic; provided a list of benefits for site access via HWY 92 instead of Stone Pine Road. 21 Jeremy Levine,
Housing Leadership
Council
Concerned that mixed-use and multi-family zoning densities are too low and that Measure D capacity will constrain the
development of housing generally.

Note: The full text of each written communication is provided at the end of this Technical Report.

Table E-3: May 9, 2023, Work Session Public Comment Index/Summary # Commenter Comment Topic(s)
1 Joy Moore,
Harmony Salon
Concerned about the Stone Pine Road housing site, traffic on Stone Pine Road, and the intersection at Main Street.
2 Rabbi Moshe Heyn Supports the Housing Element process. There is a problem that we need to solve.
3 Rocio Avila Need more affordable housing, housing needed to support children.
4 Carolina Carbajal Need more affordable housing and a "just salary," young people are leaving the area, and kids need a good place to live to be leaders.
5 Crystal Avila Housing is a necessity; young people cannot do schoolwork in crowded units/rooms.
6 Pastor Sue Holland Need more affordable housing; support service workers and children.
7 Jan Hanson Mobile home communities need to be considered. 490
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 20 # Commenter Comment Topic(s)
8 Alice Linsmeier Need housing to support children, grades improve if well housed. 9 Maria Garcia Need more affordable housing; apartments needed to reduce overcrowding.
10 Emily Glines There is a great need for more affordable housing, including for seniors who want to downsize.
11 Sean McPhetridge,
CUSD Sup.

Working on new housing development on school property for teachers and staff.
12 Mike Ferreira Be careful about reducing parking standards for development types where residents really need it. We don’t have transit. 13 Joanne Rokowsky Supports tone of Housing Element and notes the need for more affordable housing, more than RHNA.
14 Crystal (no last
name provided)
Concerned about Stone Pine Road housing site including traffic and home value impacts on Cypress Cove.

Note: Detailed meeting summary notes are provided at the end of this Technical Report and include additional summaries of each speaker’s comments.

How Community Input Was Addressed
The first public draft Housing Element has been updated to incorporate community input. Key themes and responses are summarized below.

Housing for Older Adults: The need for more affordable housing and smaller housing units that would allow older adults to downsize and stay in the community came up several times in community comments.
 Housing Element Revisions: Program 1-7 Diverse Housing Types was revised to emphasize the need for small units and/or units for older adults in new residential development.

Program 3-1 Senior and Disabled Housing was updated to acknowledge that housing suited to older adults of all income levels is needed.

Family Housing: The community wants the Housing Element to more directly address overcrowding for families that double and triple up in small housing units. This input was further informed through statements made about the impacts of such conditions on children.  Housing Element Revisions: Program 3-5 Large and Multi-Generational Households was updated to clarify BMR and Density Bonus incentives and added fee waiver incentives for affordable units developed on infill single-family lots.

Manufactured Homes: Manufactured housing and mobile home parks were identified as opportunities to provide larger and more affordable units within safe and cohesive neighborhood environments. The Housing Element includes two mobile home park site expansions - Pipeline Project AH (Hilltop Mobile Home Park, 250 San Mateo Road) and Housing Opportunity Site 5 (Canada Cove, 101 Canada Cove Avenue) - as well as a potential new manufactured housing neighborhood on Site #1 (880 Stone Pine Road).
491
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 21  Housing Element Revisions: As further described below, new Program 1-8 Diverse and Healthy Neighborhoods was added to establish provisions to maintain and enhance neighborhood diversity. Inclusion of manufactured housing is one means of doing so and is acknowledged in Program 1-8.

Stone Pine Road Housing Opportunity Site: Housing Opportunity Site #1, 880 Stone Pine Road, was the subject of many of the comments received. The City is currently working on preliminary plans for the property. Two community meetings for the 880 Stone Pine Road site overlapped with the Housing Element 30-day public review period (April 17 and May 8, 2023). The City intends to ensure that neighborhood and other community concerns are addressed as the approach to site development is further refined. Because this is an area of active discussion occurring concurrently with the Housing Element public comment period, it has been helpful to the City to hear about both concerns and hopes for development of this property.
 Housing Element Revisions: The narrative for Site #1 presented in Technical Report Appendix C – Housing Resources was updated to acknowledge input about project design, potential impacts such as traffic, and ongoing oversight and maintenance of future development.

In addition to the above changes, the following topics, although not leading to revisions to the Housing Element, are important to address to provide more information and clarity to those who made public comments.

Teacher Housing: The significant need for teacher and staff housing was mentioned by several individuals. It is notable that Housing Opportunity Site #2 (498 Kelly Avenue, the “District Office Site”), is for 60 units of such housing. The Cabrillo Unified School District (CUSD) is moving forward with a preliminary application for Housing Opportunity Site #2.

Agricultural Land Use and Farmworker Housing: Commenters asked about the City’s support for farmworker housing as well as for agricultural land uses. The City provides deep policy support for the retention of agricultural land use, which is a Coastal Act priority use. The Local Coastal Land Use Plan (LCLUP) includes policies throughout Chapter 2 (Development) and Chapter 4 (Agriculture) that support long-term retention of agricultural land uses, including farmworker housing on properties in agricultural and horticultural use, as well as on other sites. Every unit matters, and thus the strategy to facilitate development of farmworker housing in small and larger formats - both on-farm and off-the-farm – was deliberately set up in the LCLUP in anticipation of the Cycle 6 Housing Element.

Residential Densities and Measure D: The City’s R-3 and mixed-use districts have maximum residential densities of nearly 30 units/acre. A written comment suggested that these densities need to be increased to 50 units/acre. The City notes that while the buildout analysis in the LCLUP assumed 30 units/acre for these areas, it also assumed that additional units would come with affordable and mixed-income housing projects via density bonus allowances. This is already proving to be the case, such as with the City’s 555 Kelly Avenue site (pipeline project #AJ). As modeled in the LCLUP, water and sewer system capacity were found to be substantially adequate through 2040, 492
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 22 with the exception of water supply during multi-year drought conditions as identified in the Coastside County Water District’s 2020 Urban Water Management plan. Increasing the City’s maximum densities to 50 units/acre for the R-3 and mixed-use districts could result in the depletion of water and sewer system capacities before 2040. An unintended consequence would be to foreclose development of future affordable housing projects if nearer-term market rate development consumes infrastructure capacity. The comment also noted that Measure D is a constraint. The City’s analysis of Measure D in Technical Report Appendix B – Constraints presented the challenges imposed by Measure D and ways to manage them through implementation. In summary, while there is adequate capacity in Measure D for the Cycle 6 RHNA, the need for phasing and other perceived risks may be off-putting to developers. Fortunately, density bonus units are exempt from Measure D. This exemption encourages developers of market rate housing to provide affordable units to achieve higher densities and enjoy the benefit of not having to secure Measure D allocations for large portions of projects. The density of such projects could meet or exceed densities of 50 units/acre as suggested by the commenter, but in a manner that fits within the City’s infrastructure capacity.

City Council Direction
At the joint work session, the Planning Commission and City Council considered public comments and discussed numerous programs and opportunities. The City Council directed City staff to revise the Housing Element to be submitted for HCD’s review for several topics. Like the community, the Council requested more support for older adults and mobile home parks, and these topics are addressed above. Additional topics brought forward by the Council follow:

Community Character: Emphasize community character and the intent to protect community diversity.
 Housing Element Revisions: The first page of the Introduction and Executive Summary was revised to highlight community character as a priority and explain that community character is more than “small town” charm; small towns take care of each other.

Town Center Incentives: Incentivize development Downtown and pursue development of the Housing Opportunity Sites in the Town Center, including but not limited to 555 Kelly Avenue, 880 Stone Pine, and others.
 Housing Element Revisions: To further encourage housing development in the Town Center, Program 6-4 Removal of Constraints was expanded to acknowledge the City’s support for CEQA exemptions for qualifying projects. Flexible standards for infill development in Town Center are already acknowledged in Program 1-2 Missing Middle Housing Development Standards.

Neighborhood Diversity: Heritage Downtown and other parts of the Town Center area illustrate neighborhood diversity, with mixed-uses, a range of housing types, and a diverse population. New development in Town Center should contribute to that diversity through mixed-income projects and creative housing types including co-housing. For large development sites, that would create new neighborhoods, care must be taken to encourage such diversity when the neighborhood structure 493
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 23 is not yet in place. This is most applicable to the Podesta PD (Pipeline Project AI). This diversity promotes community vibrance, resilience, and access to resources from an AFFH perspective.  Housing Element Revisions: Although the concept of housing diversity was acknowledged in numerous programs, including Programs 1-3 Below Market Rate (BMR) Housing Ordinance, 1-7 Diverse Housing Types, and 3-3 Home Sharing and Cooperative Housing; a new program was added to better address the City Council’s direction. Program 1-8 Diverse and Healthy Neighborhoods calls for housing development that increases the diversity of existing neighborhoods and establishes diversity when new neighborhoods are created.

Home Sharing and Co-Housing: Co-housing is an area that is evolving and provisions to allow creative approaches should be included in the Housing Element.  Housing Element Revisions: Program 1-7 Diverse Housing Types was updated to include livework formats that may lend themselves to co-housing. Program 3-3 Home Sharing and Cooperative Housing acknowledges multiple types of housing units as well as home sharing and co-housing arrangements. The program was updated to acknowledge ownership and funding approaches.

Parking: Parking flexibility is most appropriate Downtown. Adequate parking for older adults and disabled persons needs to be supported, especially with such limited transit on the Coastside.  Housing Element Revisions: Program 1-2 Missing Middle Housing Development Standards looks to parking reductions to incentivize housing development. Because Half Moon Bay and the Coastside have limited transit options, parking is important for many lower-income families, and parking that is proximate to housing and services is very important for older adults and disabled individuals. Program 1-2 was revised to provide context for parking reductions.

ADUs and Measure D: ADUs are highly desired and the City’s efforts to increase their production have been successful. ADU affordability remains a concern, as does the capacity of Measure D, which has been significantly impacted by the increase in ADU production.  Housing Element Revisions: To facilitate ADU development and affordability, Program 1-5 Accessory Dwelling Units (ADUs) was revised to include new incentives for affordable ADU development. To address Measure D capacity, Program 6-4 Removal of Constraints was updated and now calls out this topic and offers approaches to addressing this situation.

Funding: Secure as much funding for affordable housing as possible, such as from San Mateo County’s Measure K.
 Housing Element Revisions: Program 4-6 Increased Funding for Affordable Housing was revised and Measure K funding is now referenced.

Terms: Add clarity about the terms just housing, living environments, and references to the homeless population.
 Housing Element Revisions: Definitions of the following terms are now provided in the Glossary of Terms and List of Acronyms and/or clarified in text as noted below:
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 24  Just Housing: This term has been used by the community to describe housing that is affordable, safe, and healthy.
 Homeless, unhoused, or unsheltered: These terms had been inadvertently used interchangeably in a few places in the First Public Draft Housing Element; however, they have specific meanings. The term “unhoused” was eliminated from the narrative Definitions for homeless, sheltered homeless, and unsheltered homeless were added to the Glossary. The Housing Element was updated as necessary to ensure the correct use of this terminology.
 Living Environment: For Program 1-7 Diverse Housing Types, “environments” was replaced with “spaces” to clarify a co-housing concept characterized by both private quarters and common spaces, such as shared kitchens.

Vacant Houses: Although an important concern, the City Council advised that the matter of vacant houses can be predominately addressed outside the Housing Element. The context comes from the 2020 U.S. Census which reported that there are 264 vacant homes in Half Moon Bay. It is understood that this is due to numerous factors, primarily because Half Moon Bay is a highly desirable tourist destination. Second homes, which are unused most of the year, are categorized as vacant. This is also the case for homes that are rented out as short-term vacation rentals (STRs). In both cases, housing stock inventory is diminished with such uses. With the recent certification of the City’s Short-Term Vacation Rental Ordinance by the Coastal Commission including a primary residency requirement, this threat of conversion to STRs should be substantially abated. However, the City Council continues to be interested in other approaches to taxing or otherwise working with owners of vacant homes to encourage them to sell or rent these properties.  Housing Element Revisions: Program 4-6 Increased Funding for Affordable Housing was updated to acknowledge that a tax measure could be an affordable housing funding source.

Other Revisions:
 Technical Report Appendix A – Housing Needs: This report was updated to confirm compliance with California Government Code §65590 which requires replacement of residential dwelling units occupied by low- or moderate-income persons or families in the event of demolition.
 Editorial Cleanup: The entire document was reviewed and edited to improve readability and correct typographical errors.

HALF MOON BAY COMMUNITY ENGAGEMENT DETAILED SUMMARIES
Housing Policy and Housing Element Outreach
This section of the Community Engagement Technical Report presents detailed notes taken by City of Half Moon Bay staff for engagement sessions conducted by the City. The sessions are listed below and the detailed notes begin on the next page.
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• March 3, 2021 (Wednesday evening): 18 attendees
• March 6, 2021 (Saturday morning): 10 attendees
• March 9, 2022 (Wednesday evening): 30 attendees
• March 13, 2022 (Sunday afternoon): 22 attendees
City Council and Planning Commission Joint Study Session • November 9, 2021: 83 attendees, 25 speakers (housing sites, opportunities, constraints) Focus Groups
• June 8, 2022 – Senior Coastsiders: 8 attendees
• June 16, 2022 – ALAS: 8 adult attendees as well as some school-age children Stakeholders and Service Agency Interviews: April 12, 2022 – April 19, 2022 • Coastside Hope (Service provider)
• Senior Coastsiders (Affordable senior housing and service provider) • MidPen Housing (Affordable housing provider)
• Society of St. Vincent de Paul (Service provider)
• Abundant Grace (Service provider)
• Housing Leadership Council (Affordable housing advocate) • Housing Choices (Affordable and inclusive housing advocate) • HIP Housing (Affordable housing and service provider) • Habitat for Humanity (Affordable housing provider)
• Boys and Girls Club (Service provider)
City Council Listening Sessions:

Each year the Half Moon Bay City Council hosts listening sessions to hear directly from the people who live and work in Half Moon Bay to encourage a broad range of community input regarding the City’s critical priorities. The City Council uses this input as a foundation for annual priority setting and budgeting. For several years leading up to drafting the Cycle 6 Housing Element, affordable housing has emerged as and remained a top community and City priority. Community input received from the Listening Session includes current information about housing needs and policy recommendations directly relevant to the Housing Element. The most recent two years of input, received over four separate sessions, conducted via Zoom with simultaneous Spanish translation, is summarized as follows:
• March 3, 2021 (Wednesday evening): 18 attendees
o Need rental assistance and support.
o Need more outreach about the emergency shelter (Coast House) directly to unsheltered homeless; e.g., how to get in/qualify for a room, etc.
o Need housing for all ages and stages that is affordable and available. • March 6, 2021 (Saturday morning): 10 attendees
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 26 o Appreciates the affordable housing already located in the City. o Would like to see opportunities to house refugees.
o ADUs could certainly help out.
• March 9, 2022 (Wednesday evening): 30 attendees
o Need affordable housing/ farmworker housing; thankful the City has been listening and continue to do so. (x2)
o Farmworkers deserve dignified housing too.
o Excited City Council is taking this seriously.
o Please don't stop efforts; keep this a top priority, please. o Small rural housing vs. in-town housing - Can we work on both? o Need to ask workers about their housing preferences for location and type. o Local business owners echo the need for affordable housing for staff. o Teachers are underpaid, making it hard to live on the Coastside, they need better options.
o Many families live in one room; it’s hard for children to live this way. • March 13, 2022 (Sunday afternoon): 22 attendees
o Important to keep Affordable Housing at the top of the priority list. (x2) o Need affordable housing and rental assistance.
o Would encourage the city to broaden the scope and consider already developed properties that may be underutilized, especially in the downtown area.

City Council – Planning Commission Joint Study Session:

On November 9, 2022, the City Council and Planning Commission hosted a special joint study session on the Housing Element. The agenda included a presentation of several broad categories of affordable housing types previously identified by the community as most-needed (e.g., farmworker housing, mobile homes, multi-generational family housing, and infill housing in the resource-rich Town Center area). Detailed information about specific sites intended for inclusion in the Cycle 6 Housing Element included sites owned by the City, Cabrillo Unified School District (CUSD), churches, and agricultural and other property owners. For each, the presentation covered opportunities, constraints, and potential City actions to be taken to further support development with affordable housing.

The meeting was conducted via Zoom and Spanish language translation was provided throughout.

The session was well-attended with 83 individuals, including 25 who spoke during the public forum.

Speaker comments, while not verbatim, were carefully transcribed by City staff as follows:

1. Sean McPhetridge, CUSD Superintendent: Thanked staff for the meeting invitation and for the meeting with staff. Perfect timing relative to the District’s work identifying surplus properties. Hope to present housing plans to the District board in the next few months.

2. Jack Hebb: Lifetime coastside resident, stated that there has been a crisis of displacement and affordability. In Half Moon Bay High School, 33% of the District teachers had to leave Half Moon Bay because they could not afford to live here. Anyone who does not support 497
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 27 affordable housing does not understand how housing affects their community. Wants 4- stories minimum, waive all parking requirements, need to think bigger.

3. Mike Ferreira: Looking at the RHNA number, sees 349 affordable units required and 149 market rate units. If look at the 1% growth rate limit, it is about equal to what it would take to just build the affordable housing units. Wondering how come the RHNA number is greater than 1%. Very curious about Coast House and does not know what it is or where it is. Glad to see an explanation of possibilities on Stone Pine.

4. Ana Gonzalez: Third generation from her family in Half Moon Bay, which is an honor, but it is hard to see that people that they graduated with cannot afford to live here. Lives in a onebedroom apartment and it is hard. Really need affordable housing right now. Many households are packed very tight, they want to stay here because this is where they have family.

5. Raayan: Can’t afford to live in Half Moon Bay, and would love to if he could. Council has the authority to set policies to make it affordable. But the restrictions make it very difficult to have housing in Half Moon Bay, especially the comments about teachers leaving and overcrowding. Think about this when setting policy. Need more housing. Taller buildings means more open space, so go high.

6. Greg Jamison: Good to see the information from the presentation. Hopes some good ideas come together. Hopes to share ideas back later.

7. Joann Rokosky: Has previously spoken about the need for affordable housing. Speaking in support of all the affordable housing in Half Moon Bay. Fabulous to see the detailed presentation. Encourages a wide and open vision to see what the feasibility is and to address the housing needs of this community.

8. Dora: Have been constantly moving around from house to house. Lives in one room with a family of four. They don’t have any privacy.

9. Alvaro Avila: Half Moon Bay resident for 6 years. The problem is housing. We all have families, and everything is expensive. Like the previous caller, sad to hear that kids are complaining about privacy. But can’t have it in Half Moon Bay because everything is so expensive. Really glad to keep moving forward and will support these people who are trying to help us. Hope this sort of thing goes through and that get the help, especially Latino people who need the most help. Here to support in any way that they can.

10. Ariana Vidrio: Getting more difficult to raise 3 kids. Hope that teachers can stay here. And hopefully, this goes through and the Coastside gets more affordable housing.

11. Alice Linsmeier: Great to see concrete proposals moving forward. Seems that the units skew to the side of moderate. And the very low and low are more heavily needed and should be the priority. The 20% below market rate (BMR) does not seem to be affordable to many people.

12. Belinda Hernandez-Arriaga: Representing the many families that have come through Ayudando Latinos A Soñar (ALAS) who have been struggling to find affordable housing. These are the workers that support the Half Moon Bay economy. It is inhumane to have them living the way they are. Families are packed into 1 bedroom which costs $1,500/month. Also concerned about senior farmworkers who have given so much to put food on the tables.

They should have an opportunity to have a warm home that they can be proud of. 498
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13. Juana Ruano: Thanks to everyone who is present, this year have had several meetings. Have been talking about housing, so very happy that City Council has been listening. Make $5K/month and have $8K in expenses. Where are they going to get the rest of the money? It is important to think about all of the youth and kids asking for privacy and they don’t have it. We are one heart, one world.

14. Carmella Avila: Has been living here for 16 years. Happy to say that this is a good opportunity.

It is sad that kids have no privacy. And when looking for a house – 4 kids and 2 adults – hear that it is too many people for 2 bedrooms. And the rent is too high. And God willing this will go through.

15. Guadalupe Cacho: Really happy about all this planning that is going in for the housing because we really need it. Have four living in one room including two teenagers. Difficult situation now because they are asking us to give up the room. They do not know where to go. They hope that this will all go through. Thanks to Joaquin and ALAS.

16. Lizet Cortes: Wants to agree with everything that everyone has said. Hopefully, this is a meeting that will lead to action. A local whose parents worked in the fields. As a college graduate, thought would be so much better off, but it is not the case. Very sad struggle. Was sad to see five families that were just evicted from a two-bedroom apartment. Half Moon Bay is always known as a tight-knit community that helps each other. And now everyone is struggling.

17. Judy Taylor: It really helps members of the public when informing Council if the public knows what City Council is thinking when they start to speak. Questioning 80 ADUs, because thinks there are 35 just this year. The elephants in the room are Measure D and water. And this community needs to deal with a “great project, just the wrong location.” Unless can educate that these projects are in the community’s best interest, just spinning wheels.

18. Angeles Avila: Really happy that all of this is going through. Hopes that everything turns out OK and that build these apartments. Has lived in the same house and the owner always tells us that the rent is going to keep going up. Happy that will eventually build apartments for people who really need it and people can’t all crowd together. Also, the farmworkers need the housing to do what they do. We don’t all have the same job, but we all have the same need.

19. Omar Garcia Calderon: Has lived in Half Moon Bay for 12 years. Has an 11-year-old daughter.

Hard because lives with his wife’s parents. Can’t go live on their own. Hard to find a place.

Would not want to leave here. Have friends who have left to go to Texas or Stockton. Happy to hear about the housing project. The Latinos have a huge need for housing.

20. Carolina Sandoval: I don’t have much time living in this town. I think it is a very nice town for a lot of people who do not have access to a car because everything is relatively close. But there is a huge problem where the rent is really high. I pay $700 just for the portion where I have my bed. I share my bed with my daughter. It is a very complex situation for us Latinos.

We make minimum wage, but we pay the same rent as the rest of the community. This is a positive vision that you have because we as Latinos are the ones who work really hard for this community. Thanks for the time and the project.
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21. Maria Avila: Thanks everyone. This is a great project and I hope it goes through. The unfortunate thing for us Latinos is that we have to share rooms. In the house we are in, all the rooms are rented out and there is a whole family with kids in each room.

22. Juan: Wants to congratulate everyone for this project as they are suffering concerning housing. I have lived here for 25 years. Very stressed as well. Pay $3,500 and it is going up to $4,000. I hope all this goes through. I am 100% supportive. It is truly sad to see families go through this because they have no place to live. See what have to do to one day get on the list to get a house.

23. Miguel Antonio: 30-year resident, and a carpenter with many companies. All these years have not had dignified housing. I am a dad of three kids. And so has lived in 2 rooms, having a girl who is 15, a boy who is 13, and one who is 19. All this time have never really had enough money for a house. The rents are $4K - $5K, and we only make $4K. The salaries vary with construction jobs, but also out in the fields and we have suffered because we have not had any help from the City. In the last ten years have not had any help for affordable housing and that is part of the law. For the last ten years. I want this to become a reality and not just words that are spoken. I want for all the people who are talking to form a committee, I would be included so that we could testify that you as a City Council were able to do it to help us all.

24. Francisca Vilalobos: I just want to know that where I live there are many people. We don’t have much. There are a lot of things here that can become a tripping hazard and wants this to become a reality. We have a lot of problems here. I am hoping that our family can have housing so that we have a place to live.

25. Christy: Raised their whole life in Half Moon Bay, and went to Cunha Middle School and Half Moon Bay High School. Here supporting and give her view on this issue that we have with housing. Parents did work in the fields, and it is overwhelming to see that there is not enough housing for these farmworkers. A college student currently living with parents. Has three kids of her own. Wants to see her kids grow up here and hopes a plan comes through.

Focus Groups:

Senior Coastsiders Focus Group: June 8, 2022
A City staff member and a consultant to the City facilitated the meeting via Zoom. Eight attendees provided input about housing development and policy with a focus on senior needs.

Value about living in Half Moon Bay:
• Wonderful community, friendly town, and senior-friendly • Love the Coastside and the climate
• Everyone helps each other, people are so kind
• Financial support
Priorities for housing:
• Take care of the current residents and people who give back to the community (e.g. essential workers)
• The coast would benefit from more affordable housing, including:
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 30 o Assisted living, memory care, and retirement housing
o Senior housing for people who are under 62 years old
o Housing for people with disabilities and the homeless • Shared housing: HIP Housing is a good resource for shared housing but not sure how many opportunities there are on the Coast. One option for seniors and people who need assistance is to share their homes in exchange for the provision of in-home care. • Controlled rent increases
• Mixed-use buildings with commercial spaces on the ground floor and housing above • Good quality housing for people of all ages and income levels. • Additional support for older adults
o Improved home and community-based services would help people stay safely in their homes instead of having to be moved to nursing facilities that are located over the hill. o Senior Coastsiders does a wonderful job assisting older adults with finding housing. o Amenities are needed in senior housing: picnic tables, outdoor seating, and attractive gardens with native plants all make housing more welcoming; adequate storage, e.g., for bikes, etc. and EV chargers should be included.
o Properly working streetlights help seniors (and others!) feel safer out and about at night.
o The very poor public transportation options on the coast decrease the quality of life of those who can no longer drive either because of health reasons, or because they can no long afford to maintain a vehicle.

Common areas of concern:
• Older adults:
o Long waiting lists for senior housing.
o Computer literacy: often the application process is complicated and housing forms are done online without consideration of computer literacy, blindness, accessibility o Transportation needs: can’t use public buses; shuttle service needs to be staffed and funded; seniors are left waiting for the shuttle
• Female-headed households: Twice as likely to live in poverty; 60% of women don’t have the opportunity to be a homeowner
• People with disabilities, including developmental disabilities • Large households
• Homelessness:
o State and federal decision-makers closed mental health institutions and made them homeless
o Lack of care for the homeless: Some of the homeless don’t qualify for housing support services (for example, if they are undocumented) so finding a way to assist these individuals would be helpful.
o The purchase of the hotel (Coastside Inn, which is now Coast House) for transitional housing has reduced the number of homeless individuals living on the streets and 501
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 31 greatly improved the quality of life of those who’ve made the move. Having showers and a place to do laundry has made people happier.
• Barriers to housing development:
o Lots of Coastal lands cannot be developed because of the Coastal ordinances. o NIMBYism continues to be an issue regarding new housing developments – for example, the opposition to the senior facility proposed for Moss Beach o Ensure areas on the Coast are zoned to increase housing density – but not via highrise buildings. • Systemic crisis, especially in black and brown communities; other countries don’t have the issues we have in the US; people coming to the US who can’t acquire citizenship are left on paths to homelessness.
• Housing types needed to meet the needs of households:
o Too many large houses that accommodate only one family in spaces that could have multiple units. We don’t need so many mansions!
o We have many situations on the Coast with more than one family living in singlefamily homes/apartments.

ALAS Focus Group: June 16, 2022
This meeting was held in person in the backyard of ALAS’s main office. It was facilitated by City staff and conducted in Spanish. Attendees represented low-income Latino families and farmworkers. In all, 8 adults participated, as well as several grade and middle school-age children.

Value about living in Half Moon Bay:
• Overall, it is a very safe community.
• Enjoy the small town and being close to family and friends. • Beautiful place to live, nice weather.

Priorities for housing:
• Need lower rents for essential workers.
• The City needs more affordable housing.
• With respect to the type of housing, we need family housing; many households are turned away from potential rental units if they have children. • Need housing for essential workers, including farmworkers. • Need more information about housing resources and legal assistance.

Common areas of concern:
• The current situation with housing should be considered an emergency. • Subleases without a formal lease make it difficult for tenants. • Uncontrolled rent increases, lack of improvements, and unresolved maintenance issues increase housing insecurity.
• Families are forced to live in overcrowded housing due to a lack of affordable options. • Overcrowding has a significant impact on mental health; it is especially challenging for children who need space to study and play.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 32 • Finding housing is even more difficult for undocumented households. • Need a living wage to afford housing.
• Some large homes have only one or two residents; while we have whole families living together in individual bedrooms.
• Due to overcrowding, children don’t have a feeling “of a house;” e.g., what is a living room, a kitchen, or a patio?
Stakeholder and Service Agency Interviews: April 12, 2022 – April 19, 2022 City staff invited affordable housing providers and service agencies for interview sessions in April 2022. Agencies were identified as those who are especially focused on supporting the San Mateo coastside, or those that have identified themselves to staff as seeking to increase their presence on the coast. Ten agencies participated. Interviews were unstructured and each agency was encouraged to present issues and recommendations. Input was specific to Housing Element policy and site selection. Summaries of the input follow.

Coastside Hope – April 12, 2022
Judith Guerrero, Executive Director
Need more affordable housing generally, and especially for farmworkers and greenhouse workers. • Affordable housing is great and there is never enough of it. Would need another 2 or 3 communities like Moonridge to solve the affordable housing problem. A lot of people are living in garages, closets, etc.
• Need more low-income housing. Affordable and low-income is a different market. • Farmworkers tend to have the lowest incomes. They are victims of more harassment and suffering than other community members. Farmworkers are very proud of their work. • Farmworkers are aging; the head of household working here on the farm, but not other family members. The hemp and cannabis industry is changing this. • Affordable housing communities for farmworkers solve a problem for a short time, but not for a long time.
• Coastside Hope’s support for rent relief is tied to income. Their clients have the fewest options; e.g. choosing between working and taking a child to school.

Home Ownership/Other Long-term Housing Goals: Affordable rental housing developments should be combined with other programs to help households save money to buy a home. • When a household no longer qualifies to live in an affordable housing development, they are back at ground zero.
• First-time home buyer programs would help and should be tailored to lower income, and even middle class, too.
• Wishes clients would have more awareness of future financial planning. This could be education about responsibilities that come with housing, and other financial responsibilities.

Need to take all of these considerations in mind when developing a program. • Some people are not going to retire in this community. Concerned about using housing for families who are going to stay here.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 33 • Non-documented persons do not qualify for Section 8 housing. What do you do if getting older? May move in with children. Single parents in this situation do not have many choices.

They cannot access federal programs.

Tenant Education:
• Need more protection for people who are subleasing. Need more sources and ways to educate the community about their rights as tenants.
• There is discrimination and harassment by the master leaser to the tenants. Master leaseholders overcharge and do not respect the rights of the subtenants. They utilize tactics to push out sub-tenants. This happens discretely and is not legal. Due to fear of retaliation, they do not do anything.
• Homeowners lease every room in their homes to pay mortgage, and homeowners will only accept cash. This results in limited documents, paper trail, and rights as a renter.

Local Preferences:
• Negative perception of senior housing, especially seniors who are not from our community.

How do we know that our community will be served? If going to build on the coast, need to help our community first.
• Seniors are more at risk of becoming homeless than we realize.

Use of Services and Facilities:
• Need to understand the purpose of the Coast House shelter and to make sure it is not being used like short-term farm labor housing.
• Need farmworker housing that provides flexibility for some seasonal work. Need to charge something for it; e.g. low flat fee, or a percentage of income. This is meant to help keep the place running.

Funding for Local Service Providers:
• Need flexibility, need to just be able to write a check to keep folks in their homes; appreciates the trust that the City has in their process; e.g. through the City’s Community Service Financial Assistance (CSFA) grant program.
• City requirements for grant monitoring are reasonable. • Notes that the State’s Housing is Key rental assistance program did not work for the coast because the sublease folks do not qualify. Thinks only about 20 households benefited.

Master leaseholders will not wait 3 months for rent.

Senior Coastsiders – April 12, 2022
Sandra Winter, Executive Director

Things we lack or need to support:
• There is no housing here for older adults. The homes are also not secure for coastal residents.
• More memory care housing is needed.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 34 • The Senior Coastsiders location: five non-profits on the campus; shared partnership engaging multiple people leverage individual’s generosity, non-profit capabilities, and a framework for making these links to provide a foundation for developing housing. Better than City developing housing.
• Home Sharing: ADUs support this. HIP Housing supports it. Need to provide education about how the homeowner can maintain independence, privacy, etc. in a home share relationship. • Minor Home Repair Program: Seniors cannot maintain and upkeep their own homes, and need to help people stay in their own homes. Keep them safe and housed. The City’s funding has supported this; the CDBG grant administered by San Mateo County is the primary funding source. City’s CSFA is an easy process, easy with reporting, challenge is the year-end report, due in the second week of June which means reporting two weeks before the end of the fiscal year and only a couple weeks after the home repair events. CDBG funding is more restricted. A lot of the work is in Canada Cove.
• Loves the mixed-use housing along Main Street and in Half Moon Bay Downtown, the increased density makes the City more vibrant, and more walkable.

Problems:
• For Seniors, the waiting list only opened once. Almost impossible to get into housing. If lists do open, often the only housing available is over the hill. • Have participants who live in vans and RVs; this is a real problem. Wonders about tiny home complex or RV park that is not for tourists.
• ADUs are not really affordable. Building supply cost has increased so much. It is not one thing. The architecture was expensive.
• Concern that manufactured housing does not last; it is not equivalent to a home and only lasts a certain number of years.

Outcomes/Next Steps:
• Need to provide education and resources.
• Could facilitate a focus group. Senior Coastsiders would be different from Canada Cove, and different from “free-living” older adults.

MidPen Housing - April 14, 2022
Felix AuYeung, Vice President of Business Development
In advance of the interview, MidPen provided its “Housing Element Best Practices: Lessons from Pervious Cycles.” The interview covered the recommendations, including discussion of applicability to the City of Half Moon Bay.

Link: MidPen’s Housing Element Best Practices guide is here – A Message from Matt Franklin – MidPen Housing (midpen-housing.org)

1. Master-planned sites with opportunities to maximize housing density and share infrastructure; senior housing overlay
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 35 • Midpen: Whereas an individual parcel may be zoned 30 du/acre; could spread the density limit across the plan area, and then concentrate density in different areas. May need to have a legal parcel that could have a higher density.
• City staff notes: The City already allows this approach, such as in Planned Development areas.

2. Fee exemptions for affordable housing
• Consider fee levels; providing waivers is beneficial to lower cost development and improves tie the breaker for tax credit projects. Need to hit a 15-point amenity score to even compete; the challenge is the tiebreaker which requires local resources. • Fee deferral could be just as good as waivers; e.g. if units don’t stay affordable the City could collect the fee at the time of conversion.
• Utility connections as a program would be a real contribution.

3. Reduced parking standards for affordable housing
• Presenting the City’s current DT Ratios: 1 space per studio or 1 br; 1.5 spaces per 2 br; AND ¼ space per unit for guest parking
• Reductions: 20% mixed-use, shared-use reduction; guest parking waiver DT • Have been going below 1:1 over the hill even for family housing; but Moonridge is an example that needs more parking.
• HMB may be an exception to what is being done elsewhere. Need to consider if some units will be seniors, have disabilities, etc. May be able to go below 1:1 for studios and 1 br units.

Guest parking can add up; but the reduction for mixed-use.

4. Exceptions to development standards for affordable housing • Allowing jurisdiction to have some flexibility to create exceptions without using up density bonus concessions. (e.g. overly conservative storage requirements, affordable housing developers would prefer to have a reduction granted as an exception or other means and not as a concession).
• Height – 2-stories to 3 is a 50% increase; 3-stories to 4 is only a 25% increase. Three stories is very important.

5. Affordable Housing Overlay zone
• Densities –
o 50 du/acre would be helpful to cover senior housing; e.g. exception or “senior overlay” o 40 du/acre works for families

6. Use of surplus land and City-led rezoning
• City staff notes:
o City has a very limited number of properties suitable for housing development. o The school district is studying sites; relative to the City’s Workforce Housing Overlay land use designation.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 36 o May need to consider increasing build-out and adding moderate as a qualifying affordability level.

7. Identifying housing opportunity sites owned by mission-aligned organizations • Churches
• Schools
• Other public and quasi-public owners; e.g. CCWD, SAM, etc.

8. Public sector led rezoning for affordable housing
• Look for advantageous land swaps
• Study public ownership

9. Identifying public and privately-owned sites with existing housing stock for total redevelopment to increase density:
• Half Moon Village is a good example
• Smaller scale examples of this option, e.g. housing inventory site located behind the Library; could be considered as part of a scattered site for tax credit purposes.

Conclusions/final notes:
• Scattered site policies or statements: not really needed • Asked about units for disabled – discussed past developments. Hard to do them now. County requires 5% if the project uses Measure K funds; wants the County to allow a developer to choose between 10% for homeless or 5% for disabled. After the initial lease-up, then after that, it is just the next available. Residents can request reasonable accommodations.

Otherwise, all elevator buildings are fully accessible.

Society of St. Vincent de Paul – April 14, 2022
Jim Lonergan, Executive Director
Tony Serrano, Lead Case Manager
Ginny Marans, Director of Engagement

Housing:
• We have a housing crisis; the goal is to help people get housed. • The efforts have shifted in the last five years on the Coastside; this is not going away it is getting worse, and we need to figure this out.
• Farmworkers are the most affected. Owners of farms provide housing in some cases and in others they do not.
• Eviction moratorium is ending this month and expect more families to need support. • Trying to help anyone in need throughout the County; located in 35 parishes; for Half Moon Bay it is the Our Lady of the Pillar (OLP) parish. The OLP parish is the largest conference in San Mateo County (e.g. it extends south to Pescadero). Conferences and ministries serve at the pleasure of the parish. Have 2600 volunteers throughout San Mateo County. 507
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 37 • Looked into developing affordable housing, maybe at their San Mateo location; and working with Resources for Community Development (RCD) out of Berkeley. • Focus is on folks who are precariously housed or homeless; work with Coastside Hope for the Coast, as well as HIP Housing and LifeMoves.

Grants and Local Services:
• CSFA: City’s grants – application and administration - have been going well. • St. Vincent de Paul works with core agencies and refers first to Coastside Hope because they have all the resources and programs. St. Vincent de Paul remains available as a safety net to the safety net; helping with rental assistance, food clothing, and utilities. • The $200K grants from the City for rental assistance were split between Coastside Hope and St. Vincent de Paul. Coastside Hope had to allocate first, then St. Vincent de Paul. (As of the time of the interview, St. Vincent de Paul still had $63K.) • Started working with ALAS about a month ago to help families still in need of assistance. • The scope of work with ALAS is broader; families to Coastside Hope do intake and referrals; ALAS goes to farms and visits families in their homes.
• Half Moon Bay is very different from other areas that they cover. • The Half Moon Bay City Council is doing a good job to address the housing situation and providing funding resources that will help the families.

City questions:
• What land does St. Vincent de Paul own? Noted where they have land in San Mateo, SSF, and Menlo Park; but nothing on the coast.
• Did they consider responding to the RFQ for 555 Kelly? Did receive it, but noted it was not a fit.
• What about housing at church sites? Agreed that this is a good approach with positive precedents.
• Farmworker housing – what are they seeing? Haven’t seen abuses; COVID increased awareness about farmworkers as providing essential services.

Abundant Grace - April 14, 2022
Eric DeBode, Executive Director
Lexi Hamilton, Program Manager

Coastside needs:
• Housing vouchers: nothing is available in Half Moon Bay for voucher users. Landlords are not accepting them. Only working if there happens to be a known party. • Outside the area, there are units, but outside of the area affects the individual/household, but they are not with their community.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 38 Coast House:
• Good relationship, Abundant Grace is actively referring clients to Coast House, 20 people are on the waiting list.
• Given the choice of other locations, will select Pacifica instead of OTH.

Farmworkers’ needs:
• Conducted a farmworker survey six years ago. The majority are doubled and tripled up and have lived in the area for more than 10 years. It is a tight-knit community. 300 responses. • Master lease/sublease issues
• Income is not keeping up with the cost of living.
• Studios with ensuite bathroom, 1 bedroom would be great. • How many families are experiencing homeless? Not many.

Housing Development Options:
• Pacific Ridge: Is there a way to work with the owner and city and a non-profit to rethink the project; what if the homes were 4K SF triplexes? Could use the land we already have to do more.
• Apartment buildings are predominately in Pilarcitos areas. • Need supportive housing with wrap-around services.
• What about a group home?
• Cited example of SF development with on site medical support, etc. as ideal for homeless support.

Housing Leadership Council (HLC) – April 14, 2022
Jeremy Levine, Policy Manager
HLC presented Housing Element best practices based on their policy platform: HLC Housing Element Platform - Google Docs

HLC wants to see:
• Entire Housing Element to fully consider how the City is not meeting the needs of the population, the constraints, the need to do site inventory after the AFFH analysis, etc. • Holistic Housing Element
• Policy: will look at HLC’s and other service agencies’ input (e.g., Housing Choices) • Need to describe the constraints of the Coastal Zone in the Housing Element. • Primary goal: Get two or three really great sites in each Housing Element. E.g. 90% likelihood that the site could develop.

HLC’s research on Half Moon Bay includes:
• Measure D
• Housing Element Annual Progress Reports: noted increase in ADUs 509
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 39 Next steps:
• Will continue to follow Half Moon Bay’s progress.
• Looks forward to further collaboration.

Housing Choices - April 14, 2022
Jan Stokley, Executive Director
Kalisha Webster, Senior Housing Advocate
Housing Choices provides on-site services. They are looking for a minimum of 8 units or up to 25% as part of BMR requirements and/or as part of an affordable housing development to serve this population.
• For individuals with developmental disabilities, the need is for services, not for access • They provide for clients that can live mostly independently. • Work with the Housing Authority.
• Not sure if they have clients in Half Moon Bay.

Housing Choices prepared specific policy recommendations for Half Moon Bay. The recommendations were reviewed during the interview.
• Establish and monitor a quantitative goal. Tracking the City’s success in housing people with developmental disabilities is essential to determine whether policies and programs are having an effect in overcoming historic patterns of discrimination and exclusion of people with developmental disabilities from affordable housing. A goal of 20 new Extremely Low Income housing units for Half Moon Bay residents with developmental disabilities over the period of the 2023 to 2031 Housing Element would represent meaningful progress towards the unmet housing need of this special needs group. (These would be separate from those that are “ADA”)
Sample Language: The City of Half Moon Bay shall monitor progress towards a quantitative goal of 20 new Extremely Low Income housing units that are subject to a preference for people with developmental disabilities needing the coordinated services provided by Golden Gate Regional Center to live inclusively in affordable housing. • Target City-Owned Land, Land Dedicated to Affordable Housing under the Inclusionary Ordinance and City Housing Funds to Meet City-Specific Priorities. City-owned land, land otherwise dedicated to affordable housing, and city housing funds may well be essential to the development of affordable housing that is financially feasible in high-cost Half Moon Bay. In creating guidelines for the scoring of any competitive request for proposals for these scarce resources, the City should grant additional points to affordable housing projects that address the housing needs of Half Moon Bay’s residents who are most difficult to house under existing state and federal housing finance programs--for example, by prioritizing proposals with a higher number of extremely low income units or that make a percentage of 510
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 40 units subject to a preference for identified categories of special needs people who would benefit from coordinated onsite services, including but not limited to people with developmental disabilities who benefit from services of the Golden Gate Regional Center.

Sample Language: In publishing requests for competitive proposals for any city-owned land, land dedicated to affordable housing or city housing funds, the City of Half Moon Bay shall grant additional points to proposals that address the city’s most difficult to achieve housing priorities, by, for example, providing a greater number of extremely low income units or committing to make a percentage of the units subject to a preference for people with special needs who will benefit from coordinated onsite services, such as people with developmental disabilities who receive services from the Golden Gate Regional Center.

City staff notes regarding this suggestion:
o The City does not have a lot of land, and most of it is not developable for housing due to wetlands and other constraints.
o Staff suggested that this policy approach should be broadened to include public and quasi-public lands including schools and churches.
• Local Density Bonus Priorities. Like many state and federal housing finance programs, the state density bonus program incentivizes the production of housing at the Low and Very Low Income level. But in counties like San Mateo County, with the highest Area Median Income in the state, these incentives have the effect of making much of the available affordable housing out of reach for Half Moon Bay residents who are Extremely Low Income and are thus unable to meet minimum income requirements or afford the rent assigned to the Very Low Income category. Half Moon Bay should add additional local incentives to the state density bonus law to make it more responsive to the impact of San Mateo County’s high median income on the affordability of housing for Half Moon Bay residents who are Extremely Low Income, including, for example, people with disabilities who will benefit from coordinated onsite services provided by the Golden Gate Regional Center.

Sample Language: In addition to implementing the California density bonus statute, the City shall provide an additional local density bonus, incentives, or concessions for housing projects that include a percentage of the units for people at the Extremely-low income affordability level including, for example, people with disabilities who will benefit from coordinated onsite services provided by the Golden Gate Regional Center

City staff notes regarding this suggestion: The City’s Workforce Housing Overlay could also address the intent of this suggestion. All Workforce Housing Overlay units must be affordable, with very-low and low-income affordability levels emphasized. • Reduce Parking Requirements for People with Developmental and Other Disabilities. Because most adults with developmental disabilities do not drive or own a car, the City should revise its ordinances to limit parking required for affordable units for people 511
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 41 with developmental disabilities to .5 space for each affordable studio or 1 bedroom unit and 1 space for an affordable 2 bedroom unit or larger. A similar reduction is recommended for affordable, physically accessible units.

Sample Language: In establishing parking requirements for multi-family rental housing, the City shall encourage the inclusion of people with developmental and other disabilities in affordable housing by recognizing their transit dependence and establishing lower parking ratios for units targeted to people with developmental and other disabilities than would otherwise be required for affordable housing.

• Affirmative Marketing of Physically Accessible Units: Developers are allowed to affirmatively market accessible units to disability-serving organizations in San Mateo County (i.e. Golden Gate Regional Center, Housing Choices Coalition for Person with Developmental Disabilities, Center for Independence of Individuals with Disabilities and others) but rarely take this step. Affirmative marketing is particularly needed by people with developmental disabilities who, because of cognitive, communication and social impairment, may rely on housing navigation services funded by the Golden Gate Regional Center to learn about and apply for affordable housing.

Sample Language: As a condition of the disposition of any city-owned land, land otherwise dedicated to affordable housing, the award of city financing, any density bonus concessions, or land use exceptions or waivers for any affordable housing project, the City shall require that the housing developer implement an affirmative marketing plan for physically accessible units which, among other measures, provides disability-serving organizations adequate prior notice of the availability of the accessible units and a process for supporting people with qualifying disabilities to apply.

• Extremely Low-Income Accessory Dwelling Units. As part of a larger plan to increase the supply of Accessory Dwelling Units (ADUs), the City should consider creating a forgivable loan program for homeowners who build ADUs and rent them for at least 15 years at Extremely Low Income rent levels to people with developmental disabilities.

Sample Language: Subject to funding availability, the City shall devise a program of financing for Accessory Dwelling Units subject to rent restrictions for at least 15 years at Extremely Low-Income rent levels to people with developmental disabilities who would benefit from coordinated housing support and other services provided by the Golden Gate Regional Center.
• Affirmatively Further Fair Housing. Not only is disability the highest-ranked source of Fair Housing complaints in San Mateo County, a growing body of San Mateo County data indicates that Black, Indigenous and other People of Color (BIPOC) with disabilities experience higher rates of housing discrimination and severe rent burden than either BIPOC without disabilities or whites with disabilities. Half Moon Bay offers its residents exceptional 512
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 42 community, educational and social opportunities but the severe shortage of Extremely Low Income units means that BIPOC--particularly those with disabilities--have been excluded from enjoying those community assets. Multiple barriers including high land and construction costs and limited funding make it difficult for developers to produce Extremely Low Income units that will overcome such disparities. Policies that lead to increased production of Extremely Low Income units, as well as city staff dedicated to implementing and overseeing those policies, will Affirmatively Further Fair Housing in Half Moon Bay and decrease displacement and homelessness for the most at-risk Half Moon Bay residents.

Sample Language: The City of Half Moon Bay's plans to Affirmatively Further Fair Housing for Black, Indigenous and other People of Color, particularly those with disabilities, shall include policies designed to increase the production of Extremely Low Income units, as well as adequate staff capacity to implement and monitor the impact of these policies.

HIP Housing - April 19, 2022
Laura Fanucchi, Associate Executive Director
Background regarding HIP Housing’s home sharing program:
• Just met with Michelle Dragony with Coastside Buzz to increase marketing. Currently working on ads and marketing.
• Just have two matches in HMB; have more in unincorporated Coastside. The HMB matches are considered long-term.
• Homeowners on the coast are good at making things stable for their units and tenants. • Have two clients now in HMB, younger clients looking for housing; they work on the coast and want to stay on the Coast.

Self-Sufficient Program:
• Supporting emancipated foster children; have four houses for clients. Rents are subsidized. • Also families with reduced rents.
• Provide wrap-around services.

HIP Housing as a property owner and developer:
• Has 20 properties on Bayside, and over 400 units; new construction includes 3 group share homes.
• Niche is acquisition and rehab.
• Own some, others provide tenant selection, monitoring, etc. • Have partnered with market rate developers.

What would like for the Coastside:
• Would like more support with outreach specific to the Coastside. • The City could consider working with HIP or other housing providers to help with ADU affordability.
• Can do marketing and monitoring for other cities; annual income certifications.

Other efforts:
• HIP is working on strategies to make home sharing units count toward RHNA. 513
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 43 • HIP had planned to open a coastside office but then the pandemic started. Now everything is done virtually, but remain interested in increasing our presence on the Coast.

Habitat for Humanity - April 19, 2022
Maureen Sedonaen, Chief Executive Officer
• Focus is how to make low-income folks become homeowners; help Moonridge residents become homeowners.
• Have a lot of multi-generational families in agriculture, service industry, etc. who, without subsidies, would not be able to stay here.
• HMB has a unique opportunity to take some of the potential sites and think a little bit differently about types of housing and partnerships.
o Consider ownership opportunities as part of an affordable housing development; 50-80% area medium income.
o Need to find opportunities with a for-profit or non-profit developer to carve out some units for ownership; e.g. make ownership units a portion of an affordable housing rental project. Need mixed rental-ownership for the community. • Habitat can develop small projects; e.g. 20 units because of how Habitat funds (puts up cash up front):
o 50% Mortgage
o 30% City/County (e.g. land and/or other funding sources such as grants, etc.) o 20% Philanthropy (On the Coastside there could be philanthropic partnerships that could help brown families and multi-generational families.)
• Public lands:
o Public lands to be developed with housing should be only for affordable housing. Should not include market rate units.
o A good example on a small scale is in Bolinas. Bolinas similarly is in the Coastal Zone and also has water and sewer issues. The approach is smart: they bought two lots and developed with pre-fabs, each with a single-family home and an ADU and Habitat will make them affordable at 40-50% AMI for ownership.
o School sites: The current work on this project from the School Board indicates that there may be an emphasis on market rate housing. Need to figure out some other piece of that partnership for another developer, specifically a non-profit developer to provide affordable units.
• Ideas working elsewhere:
o Redevelopment of strip malls: Seeing some conversions elsewhere. 514
City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 44 o Some cities are swapping land with churches. Faith communities are reducing and churches can work on smaller, new sites; while the city removes the church and can redevelop the larger church site with affordable housing. o Rethinking senior housing, need more affordable housing for seniors with wrap-around services, and churches have been developing such units and are providing the services. • Potential City actions:
o Impact Fees and BMR Ordinance: Consider the relationship between the two and incentivize more affordable housing by reducing impact fees. o Support a housing trust
o SB9 and/or ADU Opportunities: The law allows for ADUs to be owned under certain circumstances. SB 9 lot splits help turn a small site with just a couple of lots into a better site.

Boys and Girls Club - April 19, 2022
Jill Jacobson, Coastside Executive Director
Boys and Girls Club program and perspective: Grateful to have partnered with the City on various initiatives. Members (youth) and staff are affected by housing insecurity. • Staff:
o A lot of the program is delivered by relatively young people, e.g. local college/community college students living at home.
o Not able to pay employees enough to live here and even if they have enough money, there isn’t enough housing inventory for them.
• Members: The pandemic highlighted discrepancies in the local population:
o When the pandemic hit, all kids were sent home with a Chrome book to facilitate remote learning. Many places in the community did not have internet access. o Children and families are living in untenable situations. Families are renting a room in a house. If the family has two kids, it is unreasonable to all be on Zoom in the same small room.
o With subleases, if not named in the lease, cannot access rental support.

Current conditions:
• Families are making things work by sharing a home. Extended families living together – “extended on all fronts.”
• Transportation: People in the City core are more comfortably served (e.g. Downtown Half Moon Bay) than those outside of this area (e.g. Moonridge, El Granada, Montara) who are not as well served.
• Complication with traffic on Highway 92; during the pandemic, there was such an increase in visitors to the beach and the coast is so dependent on Highway 92, that it is a major issue for locals who need to get to services.
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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 45 Opportunities:
• Boys and Girls Club is a trusted partner and can help share information. • Sees potential for housing on Hatch School property.
• Moonridge is not within the City limits, this keeps coming up. It is a different level of attention to be part of the City.
• Community Hub: As part of CSFA funding last year, there was a collaboration concept between multiple service providers to create spaces in portables at Cunha School. Each portable would have a purpose: classroom space, counseling, etc. Each organization could reserve time to use the facility to serve families. Because it is in a centralized location, people know where to go. Everything is offered through the hub. One stop oriented to the customer; “core agency adjacent.”

Written Comments on the First Public Draft Housing Element – April 17 – May 16, 2023 Comments were submitted by the following individuals/organizations during the 30-day circulation period and are provided below.

1. Michelle Lutke

2. Sylvia Teng

3. Steve Hyman

4. Dave Powell

5. Peter Kroosz

6. Linda Goldstein

7. Marcy Barton

8. Bill Heavlin

9. Kathryn Murdock

10. Joanne Rokosky

11. KC Branscomb

12. Kirsten Loegering

13. Caeli Collins

14. Sandy Miranda

15. Rob Robinett

16. Carole Black

17. Alexandru Chitea

18. Mark Gammon

19. Keet Nerhan

20. Sha T

21. Jeremy Levine, Housing Leadership Council

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City of Half Moon Bay Housing Element – Fifth HCD Draft – September 2025 Technical Report Appendix E – Community Engagement Page | E - 46 First Public Draft Housing Element Work Session - May 9, 2023 Meeting Summary Notes Meeting Attendance:

Community Members: Approximately 35 in-person attendees, and 10 attendees on Zoom City Council: Mayor Penrose, Vice Mayor Jimenez, and Councilmembers Ruddock, Brownstone, and Rarback (all present)
Planning Commission: Chair Hernandez, Vice Chair Gossett, and Commissioners Gorn, Ruddock, and Joanes
Presentation: Mike Noce, Housing Coordinator, and Jill Ekas Community Development Director Public Comment – 14 total speakers

1. Joy Moore, Harmony Salon – Expressed concerns about Stone Pine Road housing development.

Is Stone Pine going to be the only way in and out of the project; are we considering another entrance?

2. Rabbi Moshe Heyn – Supports the Housing Element process. There is a problem that we need to solve.

3. Rocio Avila – Resident of Half Moon Bay (HMB), member of Committee for Fair Housing/lowincome housing. Has been 11 months waiting to address the Planning Commission which reviews how things are built, a certain amount of years that the City needs to provide affordable housing, nothing for 12 years. Houses have been built that are unaffordable to most. Hotels and other buildings but not enough low-income housing. Impossible to purchase a home, and rental housing is high as well. Consider construction of low-income housing.

Support our kids. Families have to share homes. Listen to us. It is time to construct just housing for the community. Immigrants deserve the right to house their families. Better future for our kids. Just housing for all.

4. Carolina Carbajal – Came to talk about what it is like to survive as a minimum-wage worker.

Start with an 8-hour work day, but most have to work longer than that. It costs $1,400 to rent a room (and noted that there are numerous additional costs such as utilities, insurance, etc.).

There are over $3,000/month in expenses but only make $2,600 per month. They are in the red. Have to share a room. Many young people are moving out of California because it is unaffordable. People have said their houses will drop in value if affordable housing is built nearby. A home is the best investment. If we had a just salary, we could afford a home. Asking for 1,000 more units of housing. We are asked why don’t we just leave; the answer is that many people have helped build this town. Wants our kids to be leaders. Need to give kids a good place to live.

5. Crystal Avila – 11 years old, identified that there are a variety of necessities and that one necessity is affordable. housing for people with people of low incomes. She is sleeping in a space that is shared and cannot focus on schoolwork. Rent is too high, and parents cannot afford it and it is sad. She goes to the march every month Downtown to walk with others asking for affordable housing. We are here and we are not leaving. 517
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6. Pastor Sue Holland – Resident of HMB, and member of Faith in Action. All are called to care for one another, we need balanced housing for all. For kids to focus on schoolwork and play.

People spend over 30% of their income on housing. Need to support our service workers. Will we work to solve our housing problems? 185 units for low and very low, but we need more.

Want to encourage housing for all income levels.